U.S. Environmental Protection Agency
Environmental Financial Advisory Board
February 11-13, 2020
Washington Marriott Georgetown
122122nd Street, NW, Washington, DC 20037
Minutes of the Meeting
Respectfully Submitted: Edward H. Chu
EPA Designated Federal Officer
Certified as Accurate: Joanne M. Throwe, Chair
Environmental Financial Advisory Board
NOTE AND DISCLAIMER: The minutes that follow reflect a summary of remarks and conversation during the meeting.
Such ideas, suggestions and deliberations do not necessarily reflect consensus advice from the Board. Formal advice and
recommendations may be found in the final advisory reports or letters prepared and transmitted to the agency
following the public meetings. Moreover, the Board advises that additional information sources be consulted in cases
where any concern may exist about statistics or any other information contained within the minutes.
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Content
Meeting Purpose 3
Attendees 3
Day 1 5
Welcome and Introduction 5
EFAB Deliberation on the Stormwater Taskforce Report 5
Section Four: Sufficiency of Funding 5
Section Five: Existing Sources of Funding 9
Section Six: Infrastructure Affordability 13
Recommendations 18
Executive Summary 31
Environmental Finance Centers 34
Day 2 38
Reconvene and Brief DFO Remarks 38
Small Community Environmental Services Resiliency Panel Discussion 38
Office of Brownfields and Land Revitalization 39
Office of Environmental Justice 40
Office of Community Revitalization 40
Office of Enforcement and Compliance Assurance 41
National Center for Environmental Economics 41
Status of Stormwater Recommendations 45
Public Comments on the Stormwater Report 46
Framing of Backhaul Alaska Session 46
Backhaul Alaska Consultation on Financing and Governance Options 46
Backhaul Alaska Report-Outs - Group 1: Structure 48
Backhaul Alaska Report-Outs - Group 2: Organization and Administration 49
Backhaul Alaska Report-Outs - Group 3: Finance and Sustainability 50
Feedback on Backhaul Alaska Consultation 51
Day 3 55
Stormwater Task Force Report - Executive Summary 55
Proposed Charge to EFAB - Opportunity Zones 58
Stormwater Task Force Report - Transmittal Letter 62
Proposed Charge to EFAB - Risk and the Cost of Capital 64
Farewell to Departing Board Members 65
Backhaul Alaska Debrief 66
Proposed Charge to EFAB - Stormwater Credit Trading 68
Voting on Proposed Charges 70
Public Comment on Proposed Charges 71
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EFAB Organization and Effectiveness
Attachments
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Meeting Purpose
The Environmental Protection Agency's (EPA) Environmental Financial Advisory Board (EFAB or Board) held a public
meeting on February 11-13, 2020. EFAB is an EPA advisory committee chartered under the Federal Advisory Committee
Act (FACA) to provide advice and recommendations to the agency on creative approaches to funding environmental
programs, projects, and activities. The purpose of this meeting was to deliberate on and finalize the Stormwater Finance
Task Force report; to provide consultation on financing and governance options for the backhaul of waste from Alaska;
and to consider proposed charges for future EFAB projects.
Attendees
EFAB Members (for full roster, see Attachment A):
- Brent Anderson, RESIGHT
- Janice Beecher, Michigan State University
- Ted Chapman, S&P Global Ratings
- Edwin Crooks, Greystone Infrastructure Advisors
- Lisa Daniel, Public Financial Management
- Yvette Downs, Sewage & Water Board of New Orleans
- Ted Henifin, Hampton Roads Sanitation District
- Craig Holland, The Nature Conservancy
- Daniel Kaplan, King County, Washington Department of Natural Resources and Parks
- Suzanne Kim, SPI Partners
- Pam Lemoine, Black & Veatch Management Consulting
- Chris Meister, Illinois Finance Authority
- Eric Rothstein, Galardi Rothstein Group
- Joanne Throwe, Throwe Environmental LLC
- William Stannard, RAFTELIS
- Angie Sanchez Virnoche, FCS Group
- Richard Weiss, Morgan Stanley
- David Zimmer, New Jersey Infrastructure Bank
EFAB Members unable to attend the meeting:
- Lori Beary, Iowa Finance Authority
- Rudy Chow, Department of Public Works, City of Baltimore
- Marie Roberts De La Parra, BMB Construction Properties
- James McGoff, Indiana Finance Authority
- James "Tony" Parrott, Metropolitan Sewer District of Louisville
- Carl Thompson, Infiltrator Water Technologies, LLC
Designated Federal Officer: Edward Chu, EPA Region 7
Additional Attendees (Based on Sign-in Sheets):
- Amanda Aspatore, National Association of Clean Water Agencies
- Lara Beaven, IWP News (Inside EPA)
- Stacey Berahzer, IB Environmental
- Brian Bohnsack, Wichita State University EFC
- Seth Brown, Storm and Stream Solutions
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- Erica Brown, Association of Metropolitan Water Agencies
- Sonia Brubaker, EPA Water Infrastructure and Resiliency Finance Center
- Medessa Burian, University of Maryland EFC
- Jacob Burney, EPA Office of Environmental Justice
- Adriana Caldarelli, Water Environment Federation
- Gabriela Carvalho, EPA Region 10
- Chuck Chaitovitz, U.S. Chamber of Commerce
- Brian Chin, American Water
- Tim Colling, Michigan Technological University
- Jennifer Cotting, University of Maryland EFC
- Andrew Crow, University of Alaska-Anchorage
- Matthew Dalbey, EPA Office of Community Revitalization
- Khristopher Dodson, Syracuse University EFC
- Steve Dye, Water Environment Federation
- Julian Gonsalves, WSP
- Elise Gout, Cadmus Group
- Tim Hamlin, EPA Region 10
- Tara Johnson, EPA Water Infrastructure and Resiliency Finance Center
- David Lloyd, EPA Office of Brownfields and Land Revitalization
- Thomas Liu, Bank of America Merrill Lynch, Water and Wastewater/SRF Group
- Michelle Madeley, EPA Office of Policy
- Al McGartland, EPA National Center for Environmental Economics
- Anthony Prince, National Rural Water Association
- Stephanie Sanzone, EPA Water Infrastructure and Resiliency Finance Center
- Surabhi Shah, EPA Office of Community Revitalization
- Martha Sheils, University of Southern Maine EFC
- Aimee Storm, EPA Office of Brownfields and Land Revitalization
- Ellen Tarquinio, EPA Water Infrastructure and Resiliency Finance Center
- Matthew Tejada, EPA Office of Environmental Justice
- Diana VanDe Hei, Association of Metropolitan Water Agencies
- Barbara VanTil, EPA Office of Enforcement and Compliance Assurance
- Britney Vazquez, EPA Water Infrastructure and Resiliency Finance Center
- Charles Walter
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Day 1
Welcome and Introduction
The meeting was announced in the Federal Register (see Attachment B) and generally proceeded according to the
agenda (Attachment C), with times adjusted as noted in these meeting minutes.
Edward Chu, the Designated Federal Officer (DFO) for EFAB, welcomed the EFAB Members and public attendees. He
acknowledged the 50th anniversary of EPA and thanked EFAB for having now developed over 100 products in the last 30
years. He noted this is a public, federally chartered advisory committee. Under FACA, all materials are available to the
public and posted to the EFAB website. The minutes of this meeting will be prepared within 90 days.
Joanne Throwe welcomed everyone. She said they have a very full agenda for the next few days. The focus of Day 1 will
be on the Stormwater Finance Task Force report. In the afternoon, there will be a panel discussion with representatives
from the Environmental Finance Centers (EFCs).
EFAB Deliberation on the Stormwater Taskforce Report
Ms. Throwe summarized the charge for the Stormwater Finance Task Force. EFAB developed a report in response to
Section 4101 of the 2018 America's Water Infrastructure Act (AWIA), which directed EPA to establish a Stormwater
Finance Task Force workgroup ("Task Force"). The purpose of the Task Force was to conduct a study on and develop
recommendations for improving the availability of public and private sources of funding for construction, rehabilitation,
operations, and maintenance of stormwater infrastructure. Task Force members were charged with identifying existing
federal, state, and local public and private sources of funding for stormwater. They were to look at affordability,
including the costs associated with infrastructure finance, and assess whether the identified funding sources were
sufficient to support capital expenditure and long-term operations and maintenance (O&M) costs. The Task Force
comprised 13 EFAB Members and 19 expert consultants from different federal, state, and local government entities.
Task Force members had two in-person meetings, supplemented by webinars and conference calls; those responsible
for a section of the Task Force report also held regular conference calls. To help inform the development of the EPA
report to Congress, EPA staff engaged in public outreach on stormwater infrastructure financing through events and
meetings in Florida, Massachusetts, Illinois, Washington DC, Virginia, Georgia, and Washington State. A summary of
some of the issues raised at those sessions was provided to the Task Force at its October 2019 meeting. The EPA report
conveying the results of the Task Force study and recommendations is due to Congress on April 23, 2020.
Ms. Throwe said the intention of this meeting is for the Board to finalize the draft Task Force report (Attachment D) and
Transmittal Letter (Attachment E). These documents will then be sent to the Administrator at EPA. EPA will develop a
short summary with a response to the Board's recommendations. The Task Force report and a summary of the public
outreach meetings will then be included in the Appendix to the report to Congress.
Ms. Throwe thanked Ellen Tarquinio for her ongoing support of the Task Force. She also recognized the Task Force
Section Leads - Pam Lemoine, Ted Chapman, and Ted Henifin - and thanked them for their leadership and coordination
on the report.
Members were provided a series of "quality review" questions prior to the meeting to guide their review of the task
force report and were asked to develop written preliminary responses to the questions. These pre-meeting comments
were shared with the full Board to aid its deliberations (Attachment F).
Mr. Henifin, Ms. Lemoine, and Mr. Chapman summarized their respective sections in the report (Sections Four, Five, and
Six detailed below). A designated Lead Discussant then facilitated a conversation on proposed revisions.
Section Four: Sufficiency of Funding
Mr. Henifin provided an overview of Section Four. Section Four looks at sufficiency of funding, specifically whether the
funding sources can support capital expenditure and long-term O&M costs to meet the stormwater infrastructure needs
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of municipalities. The approach of the Task Force was to review existing surveys, as there was not enough time to
conduct a nationwide survey on stormwater needs. With the support of an EPA consultant, Task Force members
provided synopses of these existing surveys. They supplemented their survey work with several case studies to illustrate
the state of stormwater funding in many of the big and small localities throughout the U.S. Across the surveys, they
found there is a great need for stormwater funding and estimated the funding gap to be approaching $10 billion
annually. Mr. Henifin noted that the American Society of Civil Engineers (ASCE) conducts a report card on infrastructure
in the U.S. every four years and will be adding stormwater infrastructure to the next report card in 2021. Rather than
recommend the creation of a national needs assessment, the Task Force thought it appropriate to defer to the results
from the ASCE infrastructure report card as the next national needs assessment.
Mr. Henifin moved to addressing the pre-meeting comments for Section Four. He noted the National Ground Water
Association has contributed a number of points throughout the report-drafting process. Mr. Henifin said the comment
that stood out the most regarding funding sufficiency pertained to increasing scientific research, education, and
technology transfer. Mr. Henifin said the Task Force has made such a case within its recommendations. Suzanne Kim
commented on the need for a national needs study, and Mr. Henifin reiterated the Task Force's decision to highlight the
upcoming ASCE infrastructure report card. Ms. Kim also made a comment about clearly establishing whether the
problem is the lack of capital, the ability to access existing capital, or both. Mr. Henifin responded that the Task Force
describes the problem as a combination of the two in Section Four on page 22.
Yvette Downs, Lead Discussant for the section, said Section Four successfully identifies the possible range of estimated
annual needs. She said the Board Members must ensure they identify the availability of funding for capital expenditures
compared to O&M costs. She asked them if they felt that differentiation was clear enough. She also acknowledged a
pre-meeting comment that the report confuses the meaning of funding with that of financing.
Ms. Kim thanked everyone on the Task Force for their hard work. She suggested they use the language of "capital
sources" instead of "funding." She said "capital sources" is a broad enough term to encapsulate the different categories
in the report, including operating revenue, grants, and financing.
Ms. Downs asked what the language of the charge was.
Ms. Throwe confirmed the charge encompasses both funding and financing.
Ms. Kim said they should clarify between the two, as "sufficiency of funding" is not the correct term. Are they referring
to sufficiency of financing available? Sufficiency of grants available? Is the revenue structure sufficient to be self-
sustaining? She said it was not clear when reading the report whether the Board was asking for more grants or more
financing.
Ed Crooks agreed with Ms. Kim and said the key will be to link the two terms. He said the availability and cost of
financing will depend entirely on how robust and predictable those sources of revenue are. Stronger, more predictable
sources of capital will enhance the ability to access financing.
Mr. Chu suggested the Board take all the comments on the section before responding to them.
Ms. Downs asked if the Board was satisfied with the surveys referenced in the section.
Jan Beecher agreed on the importance of differentiating between funding and financing. She proposed differentiating
between operating and capital costs as well. She suggests not conflating the source of revenue, which she views as
funding, with the means of spreading funds over time, which she views as financing. Otherwise, people will view
privatization, for example, as a source of funding when it is really a means of financing.
Ms. Downs reread the charge as follows: "Evaluate whether the sources of funding are sufficient to support capital
expenditures and long-term operation and maintenance costs necessary to meet the stormwater infrastructure needs of
municipalities."
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Ms. Beecher suggested stating at the beginning of the section that both funding and financing are insufficient.
David Zimmer acknowledged the thoroughness of the report. He prefaced his comments are based on his experiences
lending to an end-user and working for two decades in capital markets. He said he does not consider the issue to be an
insufficiency of capital. He said Wall Street will develop products to meet the extent of financial need (e.g., impact
bonds). He finds the issue is the willingness of elected officials in communities to pursue a project, borrow money, and
increase the rates of taxpayers. He said the question is how to incentivize people (e.g., regulations, increased free funds
with required behavioral changes).
Mr. Henifin noted Mr. Zimmer's point is included in Section Four on page 23. It reads, "Perhaps the biggest obstacle to
closing the stormwater funding gap is the lack of political will to increase revenues dedicated to stormwater investment
at the local, state, and federal levels." He noted this language may be too buried within the report.
Ms. Kim said Section Four does not convey that there are projects where the revenue is insufficient to make a project
self-financing because of problems like those described by Mr. Zimmer. There is no discussion of the top line. Instead,
the section focuses on operating expenses like the cost of capital. She said the cost of capital could be zero, and a
project may still not be self-financing. Section Four and the studies it cites suggest the issue is the bottom line, and the
revenue is often insufficient to make a project viable. To Mr. Zimmer's point, however, the cost of capital could be zero,
and there would still be problems. The top line needs to move as well.
Ms. Downs noted there have been several surveys, referred to within the section, that address whether communities
believe they are achieving their goals, how much they are collecting per person, and whether they believe it is enough
for their needs. It is through those surveys that the Task Force is defining the gap in stormwater funding. She said she
was unsure if there was a clear nexus between financing for capital and the collection of funds for O&M. Regardless,
these surveys do indicate that current sources of funding are insufficient.
Mr. Henifin said the intent of Section Four was to identify the gap through reviewing available surveys. In response to
Ms. Kim, he said the section included language about the insufficiency of federal funding and the difficulty of attracting
private capital because, as is stated in the report, "the expected return for third party capital is mismatched with the risk
profile of most stormwater projects." Almost all communities within the case studies also identified an inability to set
standards based on need rather than available funds. He noted most of what the Board is discussing is within Section
Four, but the information may not be organized or presented as it could or should be. He agreed with Mr. Zimmer that,
regardless of the cost of capital, the real challenge is a lack of political will to raise the revenues needed to finance
and/or fund infrastructure needs.
Ms. Downs reminded the Board there were three specific questions within the charge, and each section is designed to
respond to one of them. The recommendations section then pulls from Sections Four, Five, and Six. Section Four centers
on sufficiency of funding. Section Five is about where the money is coming from and where there is available funding.
Ms. Throwe asked if separating funding and financing in each section of the report would make things clearer.
Ms. Kim said such a separation would make the report clearer. She noted the Board is concluding there is no way to
evaluate whether the funding is sufficient because there has yet to be a comprehensive study. She said there needs to
be a sentence in Section Four that stresses the difficulty in defining the gap because of an inability to evaluate the
problem nationally.
Ms. Downs asked if Ms. Kim is suggesting the report authors add a bullet up front to acknowledge the inclusion of
stormwater infrastructure in the 2021 ASCE scorecard. The Board could then include a statement that it thinks this
scorecard will help with gathering data.
Ms. Kim agreed she would want to include something up front about the lack of and/or need for a national survey.
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Mr. Crooks reiterated that the answer to a significant portion of the charge is that there is insufficient funding; the
numbers provided by the surveys are huge. The Board should draw a conclusion that leads to questions of how to turn
funding into financing.
Ms. Kim said she is struggling with the absence of a concrete number to strengthen the report.
Ms. Downs noted while there is not the singular number that a national survey would provide, there are several bullets
in Section Four that include numbers showing the insufficiency of stormwater funding.
Mr. Henifin said the first bullet in Section Four states the funding gap is "estimated to approach $10 billion annually." He
said they extrapolated the $10 billion number as a marker from the variety of available studies.
Ms. Kim said the $10 billion figure should be brought up into the Executive Summary.
Mr. Henifin agreed.
Craig Holland thanked everyone for their support in drafting the report. He noted there are key terms provided in
Section 2.5 and suggested the Task Force members include the definitions for funding and financing there. He agreed
they should be stressing in the Executive Summary the harsh reality that stormwater funding is insufficient. He said the
Board will see in some of the recommendations that there is language about creating databases, technical assistance
platforms, and other tools to help communities develop sustainable funding streams. He said it was difficult to come up
with a uniform recommendation about how to fill the funding gap with a representative number because of the many
different sources from which communities receive their money.
Ms. Throwe directed the Board to a series of quality review questions regarding Section Four. She noted Mr. Holland's
suggestion to be explicit in the Executive Summary about the insufficiency of stormwater funding and asked if the Board
thinks this point should be clearer in Section Four as well.
Ms. Kim said it should be.
Mr. Henifin said Section Four does currently make this point up front. The first bullet of the section states there is a large
gap in funding and the annual need is estimated to be $10 billion.
Ms. Throwe asked if the charge was addressed in Section Four.
The Board agreed it was.
Ms. Throwe asked if there were any technical errors or omissions.
The Board agreed there were not.
Ms. Throwe asked if Section Four was clear and logical with the discussed modifications.
Mr. Zimmer reiterated he would like for the point on political will to be placed higher up in Section Four.
Ms. Downs noted political will is also referenced in the recommendations. She said she personally does not think
political will is the only issue; affordability is also a factor, and it affects the will of operators and politicians.
Mr. Holland clarified his earlier comment. The third paragraph of the Executive Summary clearly states funding is
insufficient. It also clearly states there are no comprehensive studies that would allow the authors to make a conclusion
as to what the exact number is. He is concerned about specifying the need for $10 billion of federal funding without
further study.
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Mr. Crooks said adding the definitions of funding and financing like Mr. Holland suggested would make things clearer. He
also stressed the Board is not asking for $10 billion in specifically federal funding; it could come from a host of sources.
Mr. Henifin agreed.
Ms. Kim emphasized the audience is Congress. Regardless of how the Board qualifies the number, the report needs to
say the estimated annual funding gap at this time is $10 billion, and the Board believes this number needs to be
researched further. She also said the Board needs to be clear that this $10 billion source of capital is not something the
Board thinks Congress should appropriate. It can come from a variety of sources.
Dan Kaplan added to Mr. Zimmer's point on the lack of political will to create revenue streams. He said there needs to
be a clear statement that the report is recommending the elimination of state barriers to the creation of stormwater
utilities and stormwater fees. He noted he did not see such a point within the Executive Summary either.
Ms. Downs asked Mr. Henifin to clarify how the Task Force reached the estimated $10 billion figure through reviewing
the surveys.
Mr. Henifin said it was a combination of the Task Force's own analysis and the work of a consultant who reviewed the
surveys. He noted they primarily pulled information about the gap in funding from the Water Environment Federation
(WEF) report. He said he would refer back to the WEF report for confirmation.
Mr. Holland said the number was $8 billion a year from the WEF report and $150 billion over 20 years from the Clean
Watersheds Needs survey.
Ms. Throwe asked Mr. Holland if he would prefer the Board not place the $10 billion number in the Executive Summary.
Mr. Holland said the Board would have to contextualize the number if it did. The Board would have to clarify the number
was the best it could extrapolate, rather than a definitive gap that, when filled, would solve the stormwater
infrastructure problem.
Ms. Throwe asked if the Board could add such context to the Executive Summary.
Mr. Holland said the funding gap is contextualized in the introduction of the report. He suggested bringing that language
into the Executive Summary. The Board could then make a direct, succinct point that the information available is
insufficient, but with what is available, the funding gap appears to be $10 billion.
The Board agreed.
Mr. Henifin said the $10 billion figure, assuming it is contextualized, will grab the attention of a reader and give an idea
as to where stormwater infrastructure needs stand.
Ms. Throwe asked if the Board could support Section Four with the modifications discussed.
The Board agreed.
Section Five: Existing Sources of Funding
Ms. Lemoine provided an overview of Section Five. Section Five delves further into the distinction between stormwater
funding and financing. It opens with a brief discussion of the role of the federal government in funding stormwater
infrastructure, recognizing the evolution of stormwater management over time. Stormwater funding is then defined as
falling into three categories: revenues (ongoing, stable and meaningful flows of funds and intermittent revenue from
various special fees and charges); capital financing (targeted capital funding for a specific project); and other resources
and approaches for stormwater management, including development by others. The bulk of Section Five addresses the
types and uses of different funding sources. Table 1 presents a detailed matrix of stormwater funding options and their
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advantages and disadvantages. To assist the Task Force in its work, EPA compiled a comprehensive database of funding
sources, primarily comprised of grants and loans (Attachment G). Ms. Lemoine noted the Task Force's difficulty in
quantifying the amount of funding available, as very few sources are strictly dedicated to stormwater. Section Five refers
to a 2019 Western Kentucky University survey and a 2018 biennial Black and Veatch survey. The Task Force used these
surveys to extrapolate that between $3.6-6.2 billion per year could be generated by the utilities identified by Western
Kentucky University. Section Five then addresses the barriers to obtaining funding, including political decision-making,
public perception, competing needs, and enabling legislation. A call-out box in the beginning of Section Five notes user
fees are the most sustainable, recurring way to begin solving this problem.
Ms. Kim appreciated the efforts of Ms. Lemoine and her team to determine revenue generation potential. She said the
Board should include how many grants and financing programs are currently dedicated to stormwater and how many of
these are competing with other potential uses. She asked if such numbers would be quick and feasible to extract.
William Stannard, the Section Five Lead Discussant, noted over the last 50 years the existing funding sources for
stormwater management were all taxes or local revenues. He said the evolution of stormwater management and the
needs for stormwater management have accelerated faster than the capabilities of existing funding sources. When
reading Section Five, he wondered about the balance between focusing on urban and non-urban stormwater
management. Larger, urban areas may have more capability than smaller areas, and the need and necessary investment
for stormwater may exceed the financial resources of smaller communities or local areas.
Ms. Beecher said the Board needs to be mindful of the presumptions they include regarding user fees. She said there are
two separate questions about user fees - whether they are politically pragmatic and whether they are the right way to
allocate costs. She acknowledged there is an impulse across the environmental sector to promote the implementation of
user fees with the idea that they are the "right" way to recover costs. She said given the challenges of allocating fees
precisely and the broad externalities associated with these services, there is a perfectly reasonable argument to make
for shared approaches. She said Task Force members should be careful not to present user fees as the default answer.
Some communities may be more than willing to explore funding combinations.
Mr. Stannard agreed. He said the Board would not want to submit that user fees are the quintessential answer to these
challenges.
Ms. Lemoine noted many of the existing taxes and other approaches have sunset clauses. She said the Board could
broaden the discussion of user fees and taxes to emphasize that they must be sustainable and recurring for the financing
they want to achieve.
Richard Weiss noted his pre-meeting comment on the draft about better addressing implementation challenges within
Section Five. He said there are difficulties in figuring out how to fairly allocate the burden between customers. As
mentioned by Ms. Beecher, one size does not fit all. A user-charge system may not work for a smaller system.
Mr. Stannard noted there are existing user charge, parcel-based structures identified in Section Five. The Board may
want to add a few sentences about the data challenges associated with them.
Mr. Zimmer asked Ms. Kim to clarify her earlier suggestion. He asked if she would think it helpful to have a list of other
funding or financing options like the Clean Water Act section 319(h) grants.
Ms. Kim said she would like to include a number so Congress would know how many grants and/or programs are
dedicated to stormwater.
Mr. Holland said he does not think it would be possible to determine the number of sources strictly dedicated to
stormwater, though the Task Force logically would want to have one. He noted the Section Five team discussed this
topic at length. It is difficult to arrive at a single number because there are a lot of different issues communities are
trying to address in terms of stormwater (e.g., green infrastructure, flooding, water quality).
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Ms. Kim suggested Mr. Holland's point be articulated somewhere in Section Five, as she was left unsatisfied without
knowing how much money had been provided for stormwater so far.
Mr. Holland noted there was a recommendation for a national database in line with Ms. Kim's comment that was edited
out of the report. The recommendation now pertains to establishing a national database of the challenges to developing
sufficient funding sources. He wondered if there should be a recommendation for EPA to create and maintain a national
database that tracks existing sources of revenues and grants.
Mr. Zimmer said not enough people look at monetizing the savings they receive when installing new infrastructure. For
example, if one is looking to reduce flooding, costs associated with things like flood insurance or the number of cars that
must be replaced decrease. He thinks these savings should be mentioned in the report, as they offset the cost of the
project. Regarding the comment about parsing urban and rural stormwater projects, he said he thinks of flood
mitigation when considering urban areas, as there are a lot of impervious surfaces. With rural and suburban areas, he
thinks of farming and water quality runoff. He said if the Board chooses to differentiate between urban and rural, there
will be a division to some extent between the different stormwater issues each face.
Brent Anderson seconded Mr. Zimmer. He thinks the Board should define the distinction between issues of stormwater
quality and stormwater quantity. He said this distinction plays into the political will discussion as well. The report
suggests water quality does not rise to the level of what people care about in the day-to-day.
Ms. Throwe reminded the Board that the Task Force had decided the charge covered both water quality and quantity.
Mr. Anderson said the Board should explicitly establish its line of thinking for that decision. He added the differentiation
between urban and rural areas is also important, as it speaks to affordability and availability. He said the needs of the
two are different, and there are solutions available to urban municipalities that simply do not exist for rural
communities. He agreed there is an emphasis on utilities and user fees running through the document that the Board
may want to deemphasize.
Ms. Downs noted "stormwater utility" seems to be used interchangeably with "stormwater user fees." She said the
Board needs to clearly address the differences between them in the key terms. She also agreed with Mr. Holland's
suggestion to include "stormwater financing" and "stormwater funding" in the key terms. She said she has some
hesitation as to how the Board would define urban and rural areas, as they would have to determine how much detail
they want to go into when differentiating between the two. She agreed they have different needs and said that is why
education is one of the main components in the recommendations. She finds education relates to multiple parts of the
report, including the implementation of user fees.
Mr. Holland said there is a clear definition of municipal stormwater in Section Two on the bottom of page 10 that
includes both flooding and water quality. He is concerned about separating out those aspects of stormwater when
defining funding purposes. He noted there has been a big trend in the stormwater space to recognize the interrelation of
these aspects of stormwater and recombine them. He said the utilities that have sufficient funding mechanisms and are
doing this well are integrated utilities. The Board will include a definition for "stormwater utility" in the key terms
section, but he does not want to break out what a utility does or does not do.
Ms. Downs clarified that her comment was that a stormwater utility and a user fee are not the same thing, yet they have
been used in the report as though they are. She said the Board should either establish that they are using those terms
interchangeably or change their language to recognize those differences.
Mr. Holland said there was a lot of concerted effort in drafting this report to define stormwater as broadly as possible
given the interrelation of aspects like flooding and water quality. He said the Board does not want to set up unnatural
silos that would result in funding being sufficient for certain aspects of stormwater but insufficient for others.
Mr. Stannard found Section Five to successfully identify and categorize the wide range of existing funding sources. He
said the Task Force did as well as it could have in determining the level of funding available.
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Ms. Throwe asked the Board Members for their takeaways when reviewing Section Five. She noted Mr. Holland's
suggestion to have a national database that tracks existing sources of revenue. She asked if the Board should include
that recommendation.
Mr. Chu said it would be beneficial to have a database to answer the charge, but he is not sure of its long-term use. He
noted EPA would have to staff and pay for its creation, and he is uncertain of how actionable it would be or if it would
lead to improved outcomes.
Ms. Downs said she had thought the database would be designed to help utilities search through and find options of
available funding for which they could apply. She noted the development of this database could be tied into the existing
recommendation about the creation of a common application. If there is a common application for grants and programs,
a user will need to know what grants and programs are available.
Ms. Throwe noted that such a database had been compiled to support the Task Force. She asked the Board if that
database is sufficient.
Lisa Daniel said they seem to be talking about two different database concepts. One database is to support the report,
and one database is an outcome of the report to create a platform for localities. She agreed with Mr. Chu that the
former would be of less value.
Ms. Lemoine explained the database to which Ms. Throwe referred was developed as part of the Task Force's effort in
drafting Section Five. It includes information like the program name, funding type, and process for applying. While the
database is not as comprehensive across all the different funding sources, she considers it very comprehensive for
grants and loans.
Ms. Kim said she could see a policy person asking how many dollars have been spent already on stormwater and what
the outcome has been of that spending.
Mr. Zimmer said the State Revolving Funds (SRFs) are responsible for providing annually the kinds of reports Ms. Kim is
describing. He acknowledged the SRF reports do not cover an entire country, but they could be a potential data point.
Ms. Tarquinio clarified the database for stormwater funding is posted online and will soon be moved to the Water
Finance Clearinghouse. She said EPA is looking into how to clearly establish it as the stormwater database created
through this report. She wondered if the recommendation should be to keep this database up-to-date and/or enhance
it. She also noted the SRF numbers Mr. Zimmer referred to are data points EPA could pull, if the Board would like to
include them in the report.
Mr. Holland agreed with Ms. Lemoine that the database is comprehensive, though potentially not as comprehensive as
it could be. He suggested the recommendation should be to support and maintain that database.
The Board agreed with Mr. Holland's suggestion.
Ms. Throwe returned to the list of quality review questions. She asked if Section Five addressed the charge as it was
given to the Task Force.
The Board agreed it did.
She asked if Section Five had any technical errors or omissions.
Ms. Downs noted there were four case studies left out of Section Five that she felt tied into the report.
Ms. Throwe said Ms. Tarquinio had made note of case studies the Task Force would be adding to the report.
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Ms. Daniel said she would like to see a couple of sentences reflective of Mr. Zimmer's point that there are potential
savings in stormwater investment.
The Board agreed.
Ms. Throwe asked if Section Five was clear and logical with the discussed modifications.
The Board agreed.
Ms. Throwe asked if the conclusions and recommendations could be supported with the discussed modifications.
The Board agreed.
The Board took a fifteen-minute break and reconvened at 11:00am.
Section Six: Infrastructure Affordability
Mr. Chu reminded the Board Members they are functioning as experts to advise the Administrator. The report
comprises a technical document, an Executive Summary, and a Transmittal Letter. The Transmittal Letter will include the
most distilled takeaways of the report. He encouraged the Board to keep these pieces in mind. He also noted one
purpose of the Executive Summary and possibly the Transmittal Letter is to bring together the sections of the technical
report and highlight the holistic points. He reminded the Board that their criteria as an independent board should not be
whether EPA would accept their recommendations. The Board is here to advise EPA on what they see. Once the report is
transmitted to EPA, EPA will have the final penmanship and authorship for the report to Congress.
Ms. Throwe said the Board needs to pull out and highlight the benefits from stormwater investment, as Mr. Zimmer
noted.
Ms. Downs said Section 3.1.1 refers to the benefits outside of stormwater. On page 14, it refers to the Federal
Emergency Management Agency's (FEMA) hazard mitigation program and how "the return on investment is four times
or even better through cost avoidance and quicker return to normalcy than a do-nothing scenario." She agreed it would
be beneficial to reiterate these benefits in Section Six to tie back to the recommendations.
Mr. Holland said the tenor of the report is appropriately technical in nature. He suggested, in the Executive Summary
and/or Transmittal Letter, the Board could more directly explain what stormwater management is, why it is important to
invest in, and why Congress should care beyond solving specific environmental issues. He noted he would like for that
language to be positive in nature.
Ms. Throwe asked if Mr. Holland could help in drafting that language.
Mr. Holland said he would.
Mr. Henifin said during the Section Five discussion there was a question about the dollar figure for the gap in funding. He
confirmed the funding gap is annual and found the source document actually refers to a $7.5 billion gap. He said the
Task Force would correct the figure accordingly.
Mr. Chapman moved forward with summarizing Section Six. Section Six focuses on affordability in two ways: the
financial capability and financial capacity of the municipality, community, or stormwater provider; and household
affordability. Section Six recognizes WEF, the Association of Clean Water Administrators, and the American Water Works
Association (AWWA) submitted a white paper to EPA in 2019 suggesting a reconsideration of the household affordability
framework. Consequently, Section Six addresses affordability as primarily a municipality concern, though it notes many
private property owners are tasked with stormwater responsibilities. The takeaway of Section Six is that the current
system is inefficient and extremely decentralized; there is a wide range as to how services are provided, where revenues
come from, and how revenues are leveraged. The bulk of Section Six is captured in Table 2 and Table 3. Because the
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provision of stormwater management services is decentralized, with many different localities, the Task Force tried to use
qualifiers like "typically" and "generally" in the tables. The tables were designed to function as a type of playbook for
local decision-makers, presenting sets of available options depending on the institutional framework of a community.
Mr. Chapman said the Task Force tried to be agnostic as to the initial revenue stream and indicate the various
opportunities and risks associated with different financing methods.
Mr. Holland, the Lead Discussant for Section Six, noted there is a lot of overlap between Section Five and Section Six. He
said that overlap comes primarily from the tables describing the sufficiency, uniformity, and capacity of the different
forms of stormwater funding and financing. He proposed the Board discuss how to combine the data in these tables into
a clear communication point that could then rise to the Executive Summary or elsewhere in the report.
Mr. Anderson noted the current levels in the table are low, moderate, high, strong, and volatile. He wondered if there
was a way to better conform this language and suggested to instead use low, moderate, and high.
Mr. Holland acknowledged Mr. Chapman described two areas within Section Six. The first is the capability of the utility
to execute projects, and the second is the capacity of the tax base to pay for whatever projects the utility wants to
execute. He asked Mr. Chapman if it would be advisable to split up the tables into those two discrete areas and then
describe capacity and capability separately.
Mr. Chapman said he is open to Mr. Holland's suggestion so long as it does not make the table too granular or busy.
Mr. Stannard said the question is what the inflection point or barrier is due to affordability. He asked if affordability has
impacted the ability of communities to raise funds to address stormwater management.
Mr. Chapman said the Task Force was not explicit in addressing that question. He finds the obstacles for affordability
and political willingness to be implied given the existence of the $7.5 billion annual funding gap. He acknowledged
certain decisions will require political will regardless of cost. If that message is not coming across explicitly, he said he
would be happy to amplify it.
Mr. Holland asked if Mr. Stannard is recommending the Task Force make a direct link between the inadequacy of
funding and the need for additional capacity that may cause an affordability concern.
Mr. Stannard said the Task Force should consider what portion of the funding gap could be related to affordability
issues. He acknowledged there are a variety of reasons for the gap, and political will may be one of the major ones, but
political will may also be driven by affordability. He said it would be helpful to make the connection more explicit that
affordability can be something that overweighs decision-making at the local level.
Ms. Beecher said she found the tables to be highly contextual. She noted the difference between property taxes and
user fees jumped out at her, as she views user fees as being more regressive. She said it is true that, when income is held
constant and someone is placed in a more expensive house, there can be a regressive effect. Generally, however, people
live in a house that is relatively proportionate to their ability to pay, whereas user fees are more like a sales tax. She
wondered if the Board should note the subjectivity of the table and how, in many cases, the outcomes could vary
depending on implementation.
Mr. Holland proposed the Board discuss whether they should remove the qualifiers in the table.
Mr. Chapman reiterated the Task Force's intention to provide a playbook or guidebook approach. He recognized some of
the statements in the tables are loaded and explained the authors chose to use qualifiers for that reason. He said he
would be open to removing the adjectives and leave the observational text but doing so would result in a loss of value in
certain parts of the table.
Mr. Holland asked Mr. Chapman how they expect lawmakers to use the inclusion of the adjectives.
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Mr. Chapman said the Task Force Members thought of the adjustives as helping address political will. Most of the text
boxes in the tables inform local decision-makers as to what path they would want to pursue or what tools they would
want to use.
Mr. Holland asked if the Board should vote on whether to include or remove the qualifiers within the tables.
Ms. Downs suggested they remove only the low, medium, and high levels. She argued taxes are regressive and noted
one can be at the lower end of the income bracket in an inherited house. She said user fees are more flexible. She would
leave the language alone but perhaps, not knowing the audience, remove the use of low, medium, and high.
Mr. Holland said that when most stormwater utility fees are created they are proportional based on impact, which
would not make them regressive by definition.
Ms. Downs clarified she meant to specify property taxes. She agreed with Mr. Holland regarding user fees.
Ms. Beecher noted the progressivity or regression of taxes depends on their design. She said it is very relative and
acknowledged it is a debated issue.
Ms. Downs said if one is on the poorer end, the issue is not debated.
Mr. Anderson said he likes the way the table is currently presented.
Ms. Throwe asked Ms. Tarquinio for her input before the Board votes.
Ms. Tarquinio echoed Mr. Holland's point that the information in the table is fairly dense and technical. She proposed
including an introduction or high-level summary at the beginning of Section Six, so the work in the table is not lost.
Ms. Throwe said having such an introductory piece could better frame the table. She supported Ms. Tarquinio's
suggestion and asked if others agreed.
Mr. Chapman agreed.
Ms. Kim agreed.
Mr. Anderson asked for clarity on what it is they are agreeing to.
Mr. Holland said they are determining the inclusion of a summary at the front of the table and voting on whether to
keep the adjectives within the table.
Ms. Throwe clarified they should consider the inclusion of a summary at the front of Section Six, rather than the front of
the subsection.
The majority of the Board agreed.
Mr. Holland disagreed, as he thought this table and the funding matrix table from Section Five have a lot of overlap. He
suggested framing the summaries of each of those tables in their respective sections, combining the tables, and moving
the combined tables to the Appendix.
Ms. Throwe asked how the Board felt about combining the Section Six table with the funding matrix from Section Five
and placing it in the Appendix.
The Board agreed.
Mr. Chu noted the timing issue and said it would be a considerable amount of work to combine the tables.
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Ms. Daniel said pursuing this suggestion would focus the reader on what the Board is trying to convey by pulling out
some of the finer technical information.
Mr. Chu agreed with the concept. He clarified Mr. Holland is suggesting changes to the tables themselves, and there is a
question as to what that would look like.
Mr. Holland explained the redundancies between the two tables. The Section Five table has a comprehensive list of
potential funding and financing sources, but there is no discussion on the capacity and capability of executing those
different sources or their advantages and disadvantages. That discussion is introduced in the table in Section Six. His
recommendation is to combine these tables, if possible. In one table, a reader could then look across taxes and general
funds, for example, to learn about what they are and the relevant issues with their implementation.
Ms. Throwe agreed with Mr. Chu that this is a heavy lift given the approaching deadline for finalizing the Task Force
report. She asked if the Board would be comfortable with EPA and the Task Force Section Leads reworking the tables to
the extent they can without returning to the Board for approval.
Ms. Downs asked if they would opt to move the tables to the Appendix if they are unable to the combine them.
Ms. Throwe confirmed that would be the alternative.
Ms. Downs said she would be comfortable with that approach.
Mr. Chu clarified there are three options: (1) move the tables as they are to the Appendix, (2) edit the tables and move
the tables to the Appendix, and (3) consolidate the tables and move them to the Appendix. He suggested Board
Members weigh in on these three options, as they progressively increase in difficulty. If the Board goes with the third
option, Mr. Chu said the Board would want to go through email review and approval, which would require additional
time.
Mr. Weiss said if they go with option two, the Board still needs to ensure the two separate tables are consistent with
one another.
Ms. Throwe said the Board does not have time for option three. She acknowledged the Members agree with moving the
tables to the Appendix. To the extent EPA and the Task Force Section Leads can eliminate obvious redundancies, they
will. She asked if the Board is comfortable with that approach.
The Board agreed.
Mr. Holland reiterated the tables will also be summarized in their respective sections. He said they should include
something in those summaries to indicate the full tables are provided in the Appendix.
Mr. Holland moved to vote on the inclusion of adjectives and qualifiers within the Section Six tables.
Seven Board Members agreed. Seven Board Members disagreed.
Mr. Holland said the Board will be doing more to summarize and contextualize Section Six. If they can do so sufficiently,
having some guide or perspective as to how they view the various options in the tables would be helpful to those
reading the report.
Ms. Beecher asked if a compromise would be to soften the language to relative terms for the qualifiers (e.g., lower,
moderate, higher). In some cases, the Board could then use "indeterminate" or "relatively" when there is a strong
subjective element or other factors coming into play.
Mr. Holland added they should also define the qualifiers they use.
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The Board voted in favor of Ms. Beecher's compromise.
Ms. Throwe moved to the quality review questions. She asked if the Task Force members have addressed the charge.
Mr. Crooks said there is a cost impact of financing they do not directly address. When there is insufficient funding to
support financing, people build projects incrementally. Each one of those incremental steps adds costs for the
municipality. The municipality then must integrate these pieces together.
Mr. Weiss reiterated his point on referencing integrated planning, which could help lower costs both with respect to
how projects are developed and to the coordination of planning, operating, and spending.
Ms. Downs respectfully disagreed with the premise that building projects incrementally is inherently wrong. She said the
Board would need to contextualize a statement about that approach, if they were to add one. She said communities
have and can decide to break projects up into pieces to give local and minority communities a better opportunity in the
bidding and competition process. She would not want to state that it is inherently wrong to have smaller projects.
Mr. Crooks acknowledged Ms. Downs' point. He said there are ways to get around piecemeal construction that are still
inclusive and allow the municipality to have the benefit of efficiency.
Mr. Chu noted the Board should be clear in articulating that household affordability was not within the charge for the
report. Otherwise, a reader will intuitively ask why they are not addressing it.
Mr. Chapman said Section 6.3 notes the intentional exclusion of household affordability but not explicitly.
Ms. Throwe asked how Mr. Chu's point could be better addressed.
Mr. Chapman said he was unsure. He noted the metrics for measuring household affordability are incredibly
inconsistent.
Ms. Downs said the report has a recommendation that references the Low Income Home Energy Assistance Program
(LIHEAP) model, for which she strongly advocated. She wondered if it would help to generally address in Section 6.3 the
percentage of the people across the country under the poverty level without being specific as to how that affects water
rates.
Ms. Throwe asked if doing so would make it seem as though the Board is addressing household affordability.
Mr. Holland suggested a compromise would be to continue emphasizing the insufficiency of funding to address needs;
naturally, a $7.5 billion annual gap will require new forms of funding and taxes. The Board could then explain that to
qualify each of the funding options listed in the report in terms of affordability goes beyond the Board's current charge.
The Board could acknowledge new taxes are going to create affordability issues for communities, particularly when
trying to make up for such a large gap. The Board could then harken back to that point in the recommendation and
state, "To blunt the impact of the additional funding and revenue streams needed to address these concerns, we are
recommending there be programs set up to assist with household affordability issues." This language would also
indicate that the Board does not expect the full $7.5 billion annual gap to be filled with federal sources of money.
Mr. Chapman agreed.
Ms. Daniel reiterated the Board should stress the cost of doing nothing somewhere in the report. The cost of doing
nothing could, in some cases, be greater than the cost of the options presented.
Ms. Kim said, for each of the sections, the Board needs to provide a paragraph summary that includes the
recommendations in the section and the context for those recommendations. The Board should not assume that readers
will read all sections of the report.
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The Board agreed.
Ms. Throwe moved forward with the quality review questions. She asked if Section Six had any technical errors or
omissions.
The Board said it did not.
Ms. Throwe asked if Section Six was clear and logical with the discussed modifications.
The Board said it is.
Ms. Throwe asked if the conclusions and recommendations could be supported with the discussed modifications.
The Board said they could.
Recommendations
Mr. Holland briefly summarized the report recommendations, organized into three categories, as follows:
Stormwater funding and technical assistance
Education of officials and the general public on the need for sustainable funding sources
Technical assistance to create sustainable funding sources
Simplification of existing federal grant and loan programs and affordability support
Creation of a common application
Expansion of the SRF program and/or Water Infrastructure Finance and Innovation Act (WIFIA) program
Federal grant funding to pay for affordability programs
Dedicated federal stormwater assistance
Comprehensive database on barriers to utility creation
Increase in Clean Water Act section 319(h) grant funding
New construction grant program
Percentage of the Farm Bill subsidy set aside for stormwater control projects and programs
Mr. Holland noted it was difficult to find comprehensive information on stormwater infrastructure needs and current
sources of stormwater infrastructure funding and financing. These recommendations address how to target more
information and uncover where the barriers are to sufficient funding.
Mr. Holland proposed reorganizing these recommendations into two buckets: the provision for additional state and
federal funding and the provision for educational and technical assistance. He noted the provision of technical assistance
is, in some cases, a form of funding. He said the Board will want to clearly determine where technical assistance is
referring to funding to increase administrative capacity and where it is about disseminating information. He also found
an important part of implementing these recommendations will be to have a greater flow of information between
localities, permittees, states, and EPA at the federal level. Additional grants and technical assistance from the federal
government would hopefully increase that flow of information and result in the creation of better programs and better
administration of those programs. Lastly, he acknowledged there is a lot of detail in the recommendation about
expanding the SRFs and WIFIA program - more so than with any other recommendation. He explained the Task Force
Members discussed the SRF options at length. Rather than make one recommendation, they chose to show a myriad of
choices and the respective advantages and disadvantages of those choices.
Ms. Throwe opened the floor to discussion.
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Mr. Zimmer said he loved the common application recommendation and supports any way in which efficiency can be
increased through standardizing processes. He said he is wholly against creating a new stormwater SRF program. He
finds the creation of another department would complicate things dramatically. By comparison, the creation of a set-
aside for stormwater makes more sense, as the infrastructure of the SRF program is already there to be leveraged. He
noted the SRF program started through a construction management grant program in the 1980s. A lot of money was
spent in the states, the states gave that money away, and it never came back. He said New Jersey turns around $3
billion, and it keeps growing every year.
Mr. Holland noted there was a recommendation on making a One Water SRF. He asked what Mr. Zimmer's thoughts
would be to that alternative.
Mr. Zimmer said he would want to think about the potential unintended consequences in bringing the SRF programs
together. He said, conceptually, it is an interesting idea, but the implementation would be very involved and complex.
Ms. Kim supported Mr. Holland's idea to recategorize the recommendations. She proposed a third category that would
then deal with measurement, reporting, and the flow of information between different government players. She noted
there is no way to monitor the impact or to understand the resources being deployed using a quantifiable metric.
Mr. Holland said perhaps there is a common reporting standard across the recommendations made in this report. He
wondered if it is a matter of reporting on the outcomes of the recommendations.
Ms. Kim agreed. The Board and EPA could then understand the progress and continuing need.
Mr. Stannard said he had not fully considered the administrative elements at the federal and state level to enact a
separate stormwater SRF. He noted the construction grant program in the 1980s provided a needed jumpstart for
systems because of the severity of the gap in wastewater treatment. That program then evolved into the SRF program.
He said the question is whether the stormwater gap is large enough to need such a jumpstart. He recognized part of the
problem with this report is that there is no definitive study on stormwater needs or the available stormwater funding.
The data indicate there is a gap, but how much of a jump start would be appropriate and, if funding was received
through a construction grant program, would it then lead to the next level of expansion for the SRFs to finance capital
expenditures?
Mr. Crooks acknowledged the previous discussion about the database of available funding and financing sources created
through this report. He suggested the Board note in Section 3.1.3 that the database is now available and should be
maintained. Currently, the first recommendation in Section 3.1.3 refers to a database that would enumerate state
barriers to implementation. He said he does not know that such a database would be productive given the extent of
interpretation involved; what could be identified as a barrier in one state could be an important policy consideration in
another. He finds the last sentence of that recommendation, which suggests the use of the 319(h) grant funds to create
an incentive framework, has greater applicability. He proposed eliminating the first recommendation as it stands and
incorporate its last sentence into the following recommendation about increasing the funding allocation through the
319(h) grant program.
Mr. Holland agreed. His concern with some of these recommendations is they do not go further to say which specific
department in EPA will, for example, maintain the database, for whom it will be maintained, for what purpose, and with
what money. He agreed the nuances would be far too challenging to outline at the state-level. He said he has a hard
time understanding why someone in Wisconsin would want to know the challenges in the state of Michigan.
Ms. Daniel proposed for the recommendation to be about developing a set of state best practices, rather than a
database.
Ms. Downs agreed. She said, from her perspective, she could stand to gain from knowing the differences between her
operations and those of another municipality or state.
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Mr. Holland suggested providing case studies of successfully implemented utilities that had to overcome a state barrier.
Ms. Downs agreed.
Ms. Beecher said she would be cautious about using the term "best practices/' as it requires a level of vetting.
Ms. Downs said she likes the way this section is written. She is not opposed to recombining the categories, but she
would not want to lose the greater meaning of the recommendations. She agreed with Mr. Zimmer's comment on page
16 to add "would create a new layer of bureaucracy" to the disadvantages of establishing a separate stormwater SRF
program. She also agreed with his comment on page 14 to add "and resiliency to the community" to the final sentence
of the recommendation. She recognized the objections to creating a separate stormwater SRF program, but she does
think it should be left in the recommendation as an option. She liked Mr. Holland's suggestion to turn the database idea
into a compilation of case studies. She noted the recommendation to create a common application presupposes the
existence and maintenance of a database.
Mr. Kaplan said he focused his review on the Executive Summary and the recommendations and then looked in the body
of the report to see if the recommendations were fleshed out. He said the Board can agree that the challenge with the
Executive Summary is finding common ground without watering down the key points. On the other hand, some of the
recommendations are so specific that they could be more easily dismissed. He said there is little that is controversial
about the recommendations for education and technical assistance. He visited the body of the report because he had
the impression that federal policy needs to encourage the support and creation of local revenue sources to solve the
stormwater gap. He said the Board must be very clear that the creation of dedicated revenue sources at the local level is
what is needed to solve the gap, and he thinks some dollar amount should be brought into the recommendations. He
then directed the Board to the recommendation regarding the Farm Bill subsidy and noted it is not supported anywhere
in the report. He wondered if, for that reason, it should be removed. To Mr. Zimmer's point, he then said there are SRFs
that do a considerable amount of lending for stormwater. It may be helpful for the recommendation to quickly identify
and highlight those SRFs as an example of what is possible.
Ms. Throwe noted Mr. Kaplan's approach to reading the document is likely to mirror how policymakers will read it. She
suggested the Board continue looking at the comments on the recommendations following the break.
Mr. Chu agreed there is a lot of conversation to be had. He noted the Board had planned to address the Executive
Summary and Transmittal Letter after the break. The Board will need to determine how to resolve almost all the issues
with the report at this meeting to move forward. He asked the Board Members to take the time at lunch to read the
recommendations, Executive Summary, and Transmittal Letter so, upon returning, they can have a plan for how to
proceed and facilitate that discussion.
The Board broke for lunch at 12:00pm and continued their discussion upon returning at 1:00pm.
Ms. Throwe said the Board would spend the next hour discussing the drafted recommendations. The agenda for the
meeting was adjusted accordingly. She appreciated the input of the Board Members thus far and noted they need to
feel comfortable with the report before moving forward.
Ms. Tarquinio incorporated the revisions of the Board Members into the draft document as Ms. Throwe moved through
each recommendation of the report. The report recommendations are provided in bolded text below.
Recommendation: Educate elected representatives, professional administrative leaders and the general public on the
need for sustainable local stormwater funding and organizational capacity through, for example, the creation of
stormwater utilities or the expansion of existing utilities into the stormwater sector.
Mr. Chu said the recommendations should flow from the report sections the Board approved earlier. He asked the Board
to think about the connections to the technical body of the document, whether these recommendations are supported,
and whether to highlight the recommendations the Board Members feel are most important.
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Ms. Lemoine clarified there are recommendations in two places within the report, the Executive Summary on page 3 and
the more detailed recommendations starting in Section 3.1.
Ms. Downs said the Board should add, "Educate elected representatives, professional administrative leaders and the
general public on the benefits and need for sustainable local stormwater funding and organizational capacity through,
for example, advocating for the creation of stormwater utilities..." She noted advocating may not be the right word.
Mr. Henifin said the word "advocating" does not properly align with the intention of the Task Force. The
recommendation had been designed around educating these individuals about how to create stormwater utilities and
the roadblocks and benefits to doing so. It was not about educating them on how to advocate for utilities.
Mr. Anderson said the way the recommendation reads right now is that the Board is discussing sustainable stormwater
funding. He thinks it would make sense to add to the educational component the need for stormwater management and
the need for funding. Doing so could also help address political resistance.
Ms. Throwe suggested the phrase in the recommendation should read, "on the need for ongoing dedicated funding," as
opposed to just "funding."
Mr. Henifin disagreed.
Mr. Anderson said the question is how to accurately link the recommendations to funding. He feels this
recommendation currently reads as educating individuals on the need for funding, but it does not acknowledge why that
funding is needed.
Mr. Tarquinio noted the next subpart of the recommendation is to educate elected representatives, professional
administrative leaders, and the general public on the need for "organizational capacity." She asked if that addressed Mr.
Anderson's concern.
Mr. Henifin said Mr. Anderson's point is covered in the last sentence of the detailed version of the recommendation in
Section Three. The sentence notes how educational goals and investment directly benefit the health, safety, and
economic opportunity for citizens and residents and the overall improvement of water quality.
Mr. Anderson confirmed the sentence to which Mr. Henifin referred is what he felt was needed. He suggested it be
shifted higher up than Section Three.
Ms. Tarquinio asked if the Board would like to see the longer, expanded version of this recommendation in the Executive
Summary rather than just in the technical portion of the report.
The Board agreed.
Ms. Beecher noted she uses the word "entity" to avoid advocating for one structural model over another. She also
wondered if, when the Board refers to organizational analysis and provide a list of strategies, they could include capacity
development.
Mr. Zimmer noted his comment to add "and resiliency of community" to the end of the recommendation. He said when
speaking to the benefits of stormwater infrastructure, particularly in terms of economic development, it is not just a
matter of water quality.
Mr. Kaplan said he would begin the recommendation with something like, "Support the expansion of technical
assistance and the development of local stormwater funding through educating elected officials." He finds the goal is to
expand local funding, the means for which is technical assistance.
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Ms. Daniel asked what Board Members think should be the primary elevator pitch to the federal government, and she
wondered if they should reorganize the recommendations, so the dedicated federal ask is first followed by the technical
assistance recommendations.
Mr. Kaplan agreed to reorganizing the recommendations as Ms. Daniel described.
Recommendation: Provide technical assistance and funding to help communities create sustainable funding sources.
This could include assistance with funding need assessments, organization analysis, grant applications, and/or
establishing a stormwater utility fee.
Mr. Holland noted in prior discussion the Board had suggested the addition of an analysis on affordability issues to tie it
back to the affordability section of the report. The Board could fit in some language about how the affordability
assessment plays into the organizational analysis piece of technical assistance.
Ms. Kim added to Ms. Daniel's comment and said the Board should explicitly recommend Congress appropriate funds
that allow for education and technical assistance. She said it would be ideal to have a dollar figure, but without one, the
Board should say "appropriate funds."
Ms. Throwe asked where the Board should incorporate this phrase.
Ms. Kim suggested the leading sentence of the category should be, "Appropriate funds to implement educational and
technical assistance." The recommendation then becomes actionable.
Mr. Chu said Ms. Kim's revision would change what Mr. Kaplan suggested.
Mr. Kaplan said he had suggested language to support the expansion and development of local stormwater funding.
From what he heard from Ms. Kim, he proposed the Board include language about enhancing and developing local
capacity in dealing with stormwater.
Ms. Kim clarified she wants to include language that speaks to the appropriation of money to support what Mr. Kaplan is
referring to.
Mr. Crooks proposed the language, "Appropriate funds that would allow EPA to support XYZ."
Mr. Kaplan and Ms. Kim agreed with this language.
Mr. Holland noted the Board had discussed regrouping the recommendations into the following two categories: the
provision for additional state and federal funding (e.g., grants, creation of utilities, federal financing) and the provision
for educational and technical assistance.
Ms. Kim reiterated her suggestion for a third category about requiring consistent reporting or some means through
which EPA would receive consistent information. She said that is not necessarily captured under the two categories.
Mr. Holland asked if the category Ms. Kim is proposing could be incorporated into the recommendation for maintaining
a national database. Otherwise, the Board would be considering a broader category on information sharing with the
community, separate from technical assistance and education.
Ms. Throwe agreed the latter would result in a broader category but recognized the importance of direct engagement in
implementation.
Ms. Kim clarified the first category is about appropriating money, the second category is asking for money for technical
assistance and education, and the third category is to require information collecting and data source maintenance. She
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finds this would be a third category because it supports and justifies the reasons for the other recommendations. She
asked how they would justify the importance of stormwater in the future without any national studies or data.
Ms. Throwe noted the Board is still on the first recommendation.
Ms. Kim said there are two discussions taking place, one on the organization of the categories and another on fleshing
out each of the recommendations.
Ms. Downs said she thought they had agreed on two categories. She agreed the Board should include something about
reporting, but she did not think it should be a third, stand-alone category. She seconded Mr. Holland's suggestion that
this point could be a part of the recommendation on maintaining a national database.
Mr. Chapman said in terms of building financial capacity of communities, the Board discussed how cost avoidance is
equally important to the enhancement of revenues, though it is hard to measure. Increasing O&M efficiency or public
education can also create financial capacity; not everything has to require appropriations.
Mr. Weiss said the second recommendation on providing technical assistance and funding to create sustainable funding
sources could be broader. Instead of talking about the creation of sustainable funding sources, the Board could use the
language "sustainable stormwater operations." He said it is not just about funding, but also operational efficiency.
Ms. Throwe said she is not sure where the Board has landed. She asked Ms. Tarquinio to review the previous discussion.
Ms. Tarquinio noted the Task Force had decided not to number the recommendations out of a concern for providing an
artificial ranking. She said the edits for the first recommendation were to add "benefit and need" for sustainable funding
and "resilient communities" to the last sentence. She suggested the Board defer the discussion on recommendation
categories for later into the meeting.
Mr. Chu said there are currently nine recommendations and three categories. He asked Mr. Holland how the Board
would put those recommendations into two bins. Otherwise, Mr. Chu would suggest keeping the three existing
categories and instead consider moving those categories up or down within the section.
Mr. Holland said it would be simple to have two categories, one for technical and education assistance and one for new
funding. The recommendations would be grouped as follows:
Technical and Education Assistance: education of officials and the general public on the need for sustainable
funding sources; technical assistance to create sustainable funding sources; creation of a common
application; comprehensive database on barriers to utility creation.
New Funding: expansion of the SRF program and/or WIFIA program; federal grant funding to pay for
affordability programs; increase in 319(h) grant funding; new construction grant program; percentage of the
Farm Bill subsidy for stormwater control projects and programs.
Ms. Throwe asked if the Board was comfortable with this approach to organizing the recommendations.
The Board agreed.
Ms. Kim said she is comfortable with not creating the third category she recommended.
Mr. Weiss said the Board should put integrated planning into the second recommendation.
The Board agreed.
Mr. Zimmer confirmed with Mr. Chu that the report is due to Congress on April 23, 2020. He asked when EPA wants the
report from the Board.
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Ms. Tarquinio said EPA would want to receive the report as soon as possible. She recognized it must be a product with
which the Board is comfortable. By the end of this EFAB meeting, if there are substantial changes that require a
subsequent call with the Board, then the Board would have to have a call the week of March 2, 2020. EPA would need to
have the report, at the very latest, by the end of that week, though such a timeline would be tight.
Mr. Zimmer said the Board will want as close to a final product as possible by the end of this meeting.
Ms. Throwe acknowledged the Board Members need to address any major concerns they have with the report, even
with the approaching deadline. Should the Board choose to have another call, however, EPA would need to go through
the process of opening it up to the public.
Mr. Chu agreed that the Board needs to be able to support the final report when it is provided to the Congress. He noted
EPA is not just waiting for the Board but is actively working on other aspects of the deliverable for Congress.
Ms. Tarquinio confirmed Mr. Chu's statement. EPA staff have also been supporting the development of the report, so
they have a sense of what to expect from the Board.
Returning to discussion of the recommendation, Ms. Kim said the Board's recommendation is not only about creating
but also maintaining. The Board wants technical assistance at the beginning and throughout the length of the project to
provide continuity.
Mr. Anderson said the concept of utility fees, while not a recommendation, subliminally floats throughout the report. He
noted the Board provides a list of different options and asked if the report should cite more of them, rather than
continually referring to utility fees as the example.
Ms. Beecher agreed. Within the recommendation, she proposed using "revenue instruments" instead.
The Board agreed with Ms. Beecher's suggestion.
Recommendation: Provide for a common application for different federal grants across all federal agencies.
Mr. Anderson asked if the Board should broaden this recommendation beyond grants.
Mr. Zimmer said, speaking as a representative of an SRF, they do not just propose in their intended use plans how they
will use the funds from that year. They also explain how they are going to use funds received over the last 30+ years. He
noted the structure of the SRF program is very different from a grant program. He said he has not thought a lot about
whether the program should include loan funds with grant funds, but he imagined it would complicate the program
dramatically for recipients like him.
The Board voted they are comfortable on the recommendation as is.
Recommendation: The SRF is an integral tool among the many infrastructure financing options available to
communities. Whether stormwater receives consideration of its own through a new SRF program, or receives less
restrictive eligibility considerations and larger appropriations within the existing Clean Water SRFs (CWSRF) or eligible
Drinking Water SRF (DWSRF) projects, it is the view of the Task Force that stormwater would benefit from an additive
- not zero-sum - recurring financial commitment from EPA. This could be achieved by the implementation of one or
more of the following, each of which is outlined below:
Create a new SRF program exclusive to stormwater programs and projects.
Expand the existing WIFIA program or fund the Army Corps of Engineer's Watershed Implementation
Plan.
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Create a specific stormwater set-aside in the existing CWSRF framework and increase
awareness/guidance on the CWSRF for stormwater projects, including the Green Project Reserve
program.
Ms. Tarquinio noted the more detailed description of this recommendation is on page 16, including the advantages and
disadvantages of each option.
Mr. Zimmer said the other recommendations are all introduced by an action verb. He suggested the Board revise this
recommendation to read, "Provide additional - not zero-sum - funds, through one of the options listed below" and then
explain that the SRF is an integral tool.
Ms. Kim said she had the same comment.
Mr. Holland noticed incongruity between the Executive Summary and the details on pages 16-17. This recommendation
as presented in the Executive Summary does not include the option of creating a One Water SRF program.
Ms. Downs noted the addition of Mr. Zimmer's disadvantage to creating a separate stormwater SRF program. She asked
if the Board could move the first sub-bullet to be third and move the third sub-bullet to be first, so the reader does not
see the creation of a new stormwater SRF program as the first option. She said someone could mistake the list for a
hierarchy, so the Board should be mindful of the presentation.
Mr. Holland suggested the Board move the sub-bullet for creating of a new stormwater SRF program to the bottom and
include Mr. Zimmer's additional disadvantage language.
Ms. Lemoine suggested all the SRF options stay together, followed by the WIFIA option. The organization would
therefore be as follows: create a specific stormwater set-aside in the existing CWSRF framework, create a One Water
SRF, create a new SRF program exclusive to stormwater, expand the existing WIFIA program or fund the Army Corps of
Engineer's Water Infrastructure Program.
Mr. Kaplan said the phrase "not zero-sum" should be replaced with "no offsets to other programs" for clarity.
Ms. Lemoine noted the first sentence cannot only reference SRF programs, as the proposed options include WIFIA. She
suggested using "existing federal programs" as a substitute.
Recommendation: Use federal funding or technical assistance to help utility customers who are financially struggling
to pay their water, sewer, and stormwater utility bills (similar to Low Income Home Energy Assistance Program,
~HEAP).
Mr. Henifin said he does not understand the technical assistance piece of this sentence. He does not know that there is
technical assistance in LIHEAP, as it is an appropriation that flows through the states to fund programs.
Mr. Crooks said he read this recommendation as applying more to the category of funding rather than to the category of
technical assistance. He also wondered if referring to water utility bills is outside of the charge.
Mr. Henifin said with One Water, bills are rolled up and whenever affordability is evaluated, it is for all water costs. He
suggested the Board include language to emphasize stormwater to ensure it is eligible for a federally funded water bill
assistance program.
Ms. Lemoine said assistance with water and wastewater would provide additional bandwidth to afford stormwater as
well, so the One Water concept is important.
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Ms. Downs suggested the language, "who are economically challenged in paying their utility charges (whether
stormwater, drinking water, or sewer)." She said many utilities may be collecting sewer fees in their stormwater fees, so
the Board cannot ignore it.
Mr. Anderson proposed the language "paying their stormwater charges," as it fits the charge and eliminates the limiting
word "utility."
Ms. Kim agreed. She said if the Board specifies "stormwater charges," it is not necessarily making someone pay
indirectly or directly.
Mr. Kaplan said, in response to Mr. Chu's comment about the role of the Board, he is willing to go beyond the
Congressional mandate. Affordability is an issue for both water and wastewater, and he feels it would be too narrow and
confusing to limit it to stormwater.
Mr. Henifin said the last paragraph in the more detailed recommendation addresses how this could be a matter of
making water costs eligible within the existing LIHEAP program or creating a separate program. In the recommendation,
referring only to stormwater charges does not eliminate the ability of the program to pay for other charges and may not
distract the reader as much.
Mr. Kaplan said his concern is the reader may not go deeper into the report.
Ms. Throwe asked if the Board could adjust the recommendation to address Mr. Kaplan's concern.
Ms. Downs shared Mr. Kaplan's concern, but she is not sure what the solution would be.
Mr. Henifin proposed the language "water-related charges."
Mr. Anderson proposed "water-related charges, including stormwater charges."
The Board agreed with Mr. Anderson's suggestion.
Recommendation: Build a comprehensive national database that enumerates state barriers to implementation of
new stormwater revenue sources such as user fees and/or any state restrictions on existing fees or charges.
Ms. Tarquinio noted that the Board had previously discussed that this recommendation refer to case studies, rather than
a database.
Mr. Crooks said the discussion this morning had been to change the recommendation to maintaining the database of
stormwater funding sources created during this process and supplement that database with case studies of successfully
overcoming barriers.
Ms. Throwe proposed the language, "Build and maintain comprehensive national case studies..."
Mr. Chapman agreed. He said the recommendation should be written in the affirmative, rather than the negative.
Ms. Kim said the recommendation was for a comprehensive national database on federal and state financing and
funding sources that could also include case studies. The idea is to maintain the compiled spreadsheet and get back as
much data as possible to understand how much funding and financing is being put into stormwater.
Ms. Daniel proposed the following language: "Build and maintain a compendium of available revenue sources and case
studies to assist states..."
Ms. Kim said there are three allocations pertaining to operating revenue: revenue sources, grants, and other financing
programs. The Board does not currently say anywhere that it wants to maintain all three.
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Ms. Daniel noted possible revenues would be any kind of revenues, whether self-generated or accessed from elsewhere.
Ms. Kim said there are also capital financing programs, which are not revenue.
Ms. Tarquinio said when the Task Force Members were putting this recommendation together, there were two things
they tried to address. The first was a national stormwater database with different funding sources and revenue types.
The second was a compendium of what is occurring in each state, notably the state barriers to prevent the pursuit of the
funding sources assembled in the database.
Ms. Kim asked if any of the recommendations capture that these databases and resources will need to be maintained.
Ms. Tarquinio said there are two different points here. She said she wants to clarify the original intention of the
recommendation, which was to look at and provide a list of the state barriers and challenges to the funding sources
provided. Ms. Kim's point is about ensuring the information is maintained.
Ms. Daniel suggested the language, "Build and maintain a compendium of possible revenue sources and case studies to
assist users in identifying generally accepted funding mechanisms."
Mr. Holland noted these case studies are supposed to help with the creation of new revenue sources. He suggested the
Board be direct and use the language, "... to assist users in the creation of new revenue sources."
Ms. Throwe turned to Ms. Kim's suggested recommendation about maintaining the information being collected and
provided.
Ms. Downs wondered if that suggestion would belong under this recommendation or under the recommendation for
creating a common application. She acknowledged that to utilize the common application, there must be an existing
database.
Mr. Holland asked if the content of Ms. Kim's recommendation and the case studies would be in the same database or
website page for someone to access.
Ms. Kim said the original intent was to highlight these case studies. She did not want to mitigate their importance.
Mr. Holland said there is a web portal for this - the EPA Water Finance Center. He suggested EPA create a page on this
web portal that contains this information. Then EPA would need funding for the administration and upkeep of that
portion of the website.
Mr. Henifin said this recommendation was intended to be about state-by-state barriers, similar to Jeff Hughes' work at
the EFC at the University of North Carolina at Chapel Hill. He noted how far the Board has drifted from that original
intention. He wondered if the Board should strike the recommendation or take up the other recommendations being
presented. Since it would be a good fit for the EFCs, he wondered if the recommendation should be to provide funding
for the EFCs to do this.
Ms. Beecher wondered how useful it would be for states to know what other states can do. She agreed it is useful for
research and to inform people about possibilities, but each state would have to work within its own institutional
frameworks. She acknowledged information always has benefits, but she was also thinking about possibly striking the
recommendation.
Mr. Anderson suggested the Board add a period after "case studies" and delete the rest of the recommendation. He
thinks for an EFC to identify what is wrong in a state or what might be done is somewhat presumptive. He asked how an
EFC would evaluate that. He said the way to address it may be through exception (e.g., Colorado allows special districts,
but Tennessee does not). He said the Board should make the recommendation affirmative, rather than pointing out or
implying what is wrong in different states without a basis for doing so.
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Ms. Throwe agreed the Board has moved away from the original recommendation.
Ms. Beecher suggested the recommendation comprise case studies and other resources. She said combining revenue
sources with case studies seems like a nonparallel. She suggested the Board keep the recommendation at a generic
level.
Mr. Kaplan noted part of every SRF application is to provide the revenue source for repayment. He asked Mr. Zimmer, if
there was an expansion of clean water lending dedicated to stormwater, whether the legislation in New Jersey would
prevent utilities from accessing that funding.
Mr. Zimmer said if the bill required certain projects to be identified and prioritized with the funds, possibly. As it stands
right now, no. He said his SRF does a lot of different projects in New Jersey, including remediation, and is not limited by
the legislation in the state.
Ms. Downs said if the Board is leaving the recommendation in, the proposed modifications are making it more useful.
She suggested changing the language to "help users identify successful stormwater funding and financing approaches."
Ms. Kim noted there are case studies, but she is asking about a compendium of federal grants and programs.
Mr. Henifin said the Board should put what Ms. Kim is referring to in the common application recommendation. Mr.
Henifin voted with Ms. Downs to drop this recommendation.
Mr. Stannard noted this was his least favorite recommendation.
Mr. Zimmer explained why he believes this recommendation should be included. Camden County Municipal Utility
Authority (CCMUA), in a poor area in New Jersey, was run by a visionary Andy Kricun. Mr. Kricun borrowed over $200
million in the last 20 years to update CCMUA's plan. The amount of money he saved in O&M costs because of these new
projects was so great that he could address non-revenue producing projects like stormwater issues and odor reduction
issues. He was still able to drop the per annum rate that he charged from $337 to $315. Mr. Zimmer said a report on this
story is being developed with the intent to share it with every mayor and system in New Jersey. The storyline is one
needs to invest to save. He finds it is a case study that every politician in the state should get behind, and similar case
studies should be made available to others in the nation. There are case studies about investment returns and benefits
that will be very helpful for other systems to read. If there was a central place where he could go for such information,
he would want it.
Ms. Daniel asked if EPA already has a compendium of case studies.
Ms. Tarquinio said EPA does not have one that addresses these state barriers and gaps. She noted, through the process
of creating the report, the Board has now provided over 20 case studies.
Mr. Anderson seconded Mr. Zimmer's comment. He thinks the real value of this recommendation is at the state level.
Mr. Holland said the Board will have to include that there is a need for funding to build and maintain this case study
platform.
Ms. Throwe asked for a vote on whether to include the recommendation with the proposed modifications.
The majority of the Board voted to leave the recommendation in the report with the aforementioned modifications.
Recommendation: Increase annual funding allocations for and modify the 319(h) grant program to allow and
encourage local capacity building, utility fee study and implementation, asset management, and remove restrictions
on use of grants funds for Municipal Separate Storm Sewer System (MS4) permit compliance.
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Mr. Chapman noted the Board Members should specify they are speaking about financial capacity, not physical system
capacity.
Mr. Henifin said it is not just financial capacity, though. It is also technical capacity. He agreed it was not physical.
Mr. Crooks said the Board should leave the language as is, so it is all encompassing.
The Board voted to keep the recommendation.
Recommendation: Develop a new construction grant program specifically for stormwater projects, similar to the
federal Municipal Construction Grants Program that funded the construction of wastewater treatment plants.
Mr. Zimmer asked why this recommendation is not included as one of the sub-bullet points under the recommendation
to expand or alter the existing SRF program.
Mr. Henifin said if someone sees this suggestion included in the SRF recommendation, they will likely think of it as a loan
program. The intention of this recommendation was to have it stand on its own as a construction grant program.
Mr. Zimmer said he understood Mr. Henifin's point.
Ms. Throwe asked for a vote.
The Board voted in support of this recommendation.
Recommendation: Given the link between agricultural pollution and mandated stormwater pollutant reduction
targets for impaired streams, a Farm Bill Federal subsidy dedicated to stormwater programs would also be valuable.
Require 10 percent of US federal farm subsidies (all programs) be re-directed toward stormwater/nonpoint impacts in
same watershed where recipient farm is located.
Ms. Kim asked how they arrived at 10% as a set-aside.
Mr. Henifin said it was an arbitrary amount to get to approximately $2 billion a year. He felt less money would not be
worth it and much more would be a stretch. He noted the Task Force members spoke a lot about new programs and
funding, but they did not determine a way to get to revenue generation to add to the bottom line. There is a lingering
question of how the federal government will fund the Board's recommendations. Mr. Henifin also recognized 60% of the
nutrient sediment load in the Chesapeake Bay is from agricultural land and in the Gulf of Mexico it is 70%.
Mr. Kaplan asked if, given the time frame, there would be enough time for a consultant to do a short piece on the
importance of agricultural runoff as a source of pollution.
Ms. Throwe said that would not be possible by the deadline.
Ms. Tarquinio agreed. She said the Task Force Members discussed whether they should look at agricultural issues,
specifically runoff, and decided it would be too large in scope. They also returned to the language in AWIA and found it
references a lot of stormwater infrastructure that is fairly tied to developed areas. They ultimately decided it was
outside the purview of this specific request.
Mr. Holland said this recommendation would raise more questions than it answers, and it does not get at the heart of
what it is trying to do. He also finds it would be politically toxic. He noted there is a Natural Resources Conservation
Service (NRCS) program that provides funding for field practices and watershed remediation. He does not think the
Board has enough time to craft a new recommendation that would expand the NRCS program to provide the type of
funding sought through this recommendation. His personal preference would be to remove it.
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Mr. Zimmer seconded Mr. Holland. He said agriculture is one of the oldest and most powerful constituencies in the
country, and he does not see this recommendation as feasible. He suggested one option may be for Congress to give
10% of agriculture subsidies to EPA to create a program that states could use for the farming community.
Ms. Kim agreed with Mr. Holland that the Board should strike this recommendation. She considers it the Achilles heel of
the report and a potential reason for members of Congress to dismiss the other findings.
Ms. Downs agreed. She noted the Task Force did nothing in the report to explain this recommendation further. She
would rather see something acknowledge that things need to start moving in this direction. She wondered if the Board
could propose studying the impact between farming and stormwater. She noted there are likely a lot of studies like that,
but the Board could acknowledge it without starting a war with the agricultural sector.
Mr. Anderson said he likes the idea of a recommendation of this kind. He noted how a lot of the report is directed at an
urban or built environment. The Board ignores what they know are documented agricultural contributions. He said the
Achilles heel is the inability to support the 10% figure. As opposed to studying the issue, he suggested the Board say the
agricultural subsidies should be conditioned on compliance with stormwater best management practices. Presumably,
subsidy recipients must comply with federal laws to receive the subsidy anyway. He agreed with Mr. Zimmer that there
are powerful lobbies playing both sides, but the job of the Board is to make a recommendation. He said to ignore the
contributions of agriculture to stormwater is an issue.
Mr. Henifin said the recommendation was designed to acknowledge that farmers are doing what they can. This
recommendation is a way to redistribute some of the federal dollars from the Farm Bill. He noted he did not expect it to
reach the final draft of the report, but he agrees there is value in having a discussion-starting recommendation in the
report. He suggested maybe it is not a matter of citing 10% specifically but rather "a portion" of farm subsidies. He
noted a lot of the money from farm subsidies goes to large farms and rich farmers.
Mr. Zimmer suggested slightly revising the language to, "consider providing a portion of the annual appropriations to X."
In that way, the Board is not saying it should be required or placing a specific percentage on it.
Mr. Chu said if the Board decides to remove this recommendation, one way to proceed would be to address agriculture
as a separate topic. There are a lot of constituents in the federal government and in state governments who are
interested in it, and he thinks it is worthwhile to have a more deliberate approach to the topic. Tomorrow, the Board will
have a panel to learn more about what different offices in EPA are working on with regards to small communities. The
Board could have a similar panel specific to what is happening in the agricultural space. One of his observations is there
is nothing in the technical report that addresses this issue. Mr. Chu stressed he is not passing a judgement about
whether it should be included but rather noting the existence of a different path forward on the topic. It is an area a lot
of people are working in, and the more information the Board has as to the regulatory and monetary constraints of
farmers, the better set of recommendations it could develop.
Mr. Holland agreed with Mr. Chu. He said Section 2.4 specifically notes the report does not address agricultural water
pollution. He noted if the Board was to consider a recommendation to help the funding gap, there is the Environmental
Quality Incentives Program (EQIP) through NRCS that exists to address water quality challenges on farms.
Mr. Henifin said the Board should strike the recommendation rather than try to find a compromise.
Ms. Daniel said she liked Mr. Holland's point. If there is a program for which Board Members could suggest increasing
funding and affect the agricultural space, this would be their opportunity. She noted this is also the Board's opportunity
to have direct access to Congress, rather than have their report end at EPA. She does not want to take that opportunity
for granted.
Ms. Throwe asked for a vote on how to proceed with the recommendation.
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The Board tied between striking the recommendation and including it with modifications. No one on the Board voted to
leave the recommendation in its current state.
Ms. Kim clarified there are two potential modifications. One is to redirect money going towards agriculture. The other,
which she preferred, is to add money to an existing program to gain allies in stormwater.
Ms. Daniel suggested the language, "Consider providing additional funding to EQIP and consider designating that
funding towards stormwater projects."
Mr. Holland asked Ms. Throwe if EQIP would be the right program to specify.
Ms. Throwe said EQIP is one of the potential programs, but there is a match-concern and a concern for the availability of
funding. EQIP may be maxed out for this year, and demand is significant. If the Board was to recommend expanding
EQIP, it would want to consider a specific designation for stormwater.
Ms. Downs asked if EQIP is a farm program.
Ms. Throwe said EQIP is a U.S. Department of Agriculture (USDA) program within NRCS.
Mr. Henifin said this recommendation was never intended to deal with agriculture and its impact on stormwater. He
reiterated how the report does not address agriculture at all.
Ms. Throwe agreed with Mr. Henifin. She is worried about the Board going down the path of agriculture. She held a
second vote as to whether the Board should remove this recommendation from the report.
The majority of the Board agreed to delete the recommendation.
Mr. Chu asked Mr. Zimmer, who voted to keep the recommendation, if he could accept this change.
Mr. Zimmer said he could.
The Board took a five-minute break before reconvening at 3:34pm to discuss the Executive Summary.
Executive Summary
Ms. Throwe noted the recommendations in the Executive Summary would be updated to reflect the Board's recent
modifications.
Mr. Kaplan asked if it would be possible to receive a draft of the recommendations to then review the Executive
Summary on Thursday morning.
Ms. Tarquinio said she would be able to revise the recommendations tomorrow.
Mr. Chu asked if it would be possible to receive something from Ms. Tarquinio by the end of the day tomorrow. The
Board Members would then review them on Wednesday night to be able to discuss on Thursday.
Ms. Kim confirmed they are referring to the recommendations within the Executive Summary.
Ms. Tarquinio said she could provide the redrafted recommendations in line with Mr. Chu's proposed timeline.
Ms. Throwe moved to discussing Section One, the opening of the Executive Summary. She asked if the Board had any
proposed changes.
Ms. Downs said, at the end of the second paragraph, the report starts to use "stormwater utility fees" and "stormwater
user fees" interchangeably.
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Ms. Kim asked about the role of the different sections within the Executive Summary. She stressed it is the most
important document of the report and finds it needs to serve three purposes - educating the layman on what
stormwater is, explaining why it is important, and presenting the recommendations in a digestible way. She believes the
purpose of the report should be the last thing talked about in the Executive Summary.
Ms. Throwe asked for feedback on Ms. Kim's comment.
Angie Sanchez agreed with the three purposes listed by Ms. Kim. She said the reader should understand what
stormwater is and why they should care. She said the report could also note that, without political will, there could be
serious consequences.
The Board voted in agreement with this suggestion.
Ms. Throwe moved to discussing Section 1.1, "Infrastructure Funding Task Force Report and Charge."
Ms. Kim said Section 1.1 should be at the end of the Executive Summary.
Ms. Downs disagreed. She said the charge should be upfront to clearly identify why the Task Force wrote the report.
Mr. Crooks seconded Ms. Downs' comment. He thinks the Board needs to explain why they have developed the report,
frame the questions, and present the recommendations.
Ms. Throwe asked for a vote.
The Board agreed to keep Section 1.1 where it is.
Ms. Tarquinio asked if the Board still wants to add "and financing" to each of the bullets in Section 1.1.
The Board agreed.
Ms. Throwe moved to discussing Section 1.2, "Local Stormwater Funding Efforts."
Ms. Downs questioned the first sentence of the second paragraph which reads, "Conversations in recent years are
shifting from 'how to develop stormwater utilities' to the need for innovative funding strategies." She wondered if
conversations about stormwater have completely shifted, as it suggests. She said it would be more appropriate to say,
"Conversations in recent years have begun to shift..."
The Board agreed.
Mr. Holland said this is where the report should start building the case for the lack of sufficiency in funding and for the
recommendations the Board is making to address it. He does not feel the report makes a strong enough case in Sections
1.2 or 1.3 about the gaps and the justification for why the Board is focused on the two recommendation categories.
Mr. Kaplan added the report needs to make clear that there is inadequate funding at the local level, the local
communities need technical assistance in creating and managing their stormwater utilities, and that assistance can be
used to help evaluate some innovative programs. He finds having an entire paragraph on the various integrated
programs is detracting from the message that funding at the local level needs to be developed and expanded.
Mr. Zimmer asked if the Board is looking to add "and financing" to every time the word funding is used in the report. If
so, he said he has an issue with the notion of "insufficient funding and financing." He reiterated, as a capital markets
professional, it is not an issue that there is a lack of financing. If someone says they want to borrow funds from him, he
will find them funds. If someone says they do not have the monies locally to support a local financing program, that is a
very different issue.
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Ms. Tarquinio said her understanding was the addition of "and financing" would just pertain to the sub-bullets in Section
1.1 that detail the tasks with which the Task Force was charged. As such, Mr. Zimmer's comment would not apply.
Mr. Weiss said the reference to green bonds in the second paragraph of Section 1.2 should include "sustainability
bonds."
Chris Meister agreed with Mr. Weiss.
Ms. Kim said, building upon Mr. Holland's comment, Sections 1.2 and 1.3 should be combined into one problem
statement. She said the problem statement needs to support the two categories of recommendations. Specifically, it
needs to speak to the lack of capacity, or why programs need to be funded that provide capacity building. It also needs
to specify that the Board does not know the exact numbers, which is why additional programs dedicated to stormwater
are needed.
Ms. Throwe asked if others agreed with Ms. Kim.
Ms. Downs said she finds it to be less confusing if the report splits up local and federal stormwater funding. She does
think the distinction needs to be quantified more.
Mr. Anderson said Section 1.2 is more about how the increasing awareness of the problems and advancing potential
mechanisms. It does not tie in as closely as he would think to local funding efforts. In the next paragraph, there is a
statement that stormwater is as important as the federal highway system. Mr. Anderson noted there is a lot of opinion
in that statement and suggested the Board rephrase it. He also said the report needs a quantitative statement of the
problem and to add a line that defines why local stormwater funding is inadequate. Doing so would allow for a natural
transition into Section 1.3, "Federal Stormwater Funding Support." Section 1.3 then leads into the recommendations
and the need for appropriations.
Mr. Crooks proposed focusing on the problem statement or funding challenges in Section 1.2. It could have a lead-in
paragraph about the multiple-billion-dollar shortfall. Then subsection 1.2.1 would focus on local funding and subsection
1.2.2 would focus on federal funding. With this approach, both local and federal are captured under a problem
statement up front and quantified in a way that captures the entire market.
Ms. Beecher asked about the inclusion of state funding, as the report currently references local and federal.
Mr. Crooks proposed one section for state and local funding and a second section for federal.
The Board agreed with Mr. Crooks.
Ms. Throwe said Ms. Tarquinio would revise the recommendation portion of the Executive Summary.
Ms. Tarquinio said she would also try to integrate the other modifications as much as possible before Thursday.
Mr. Chu asked if it would be possible for a subset of the Board to integrate the other proposed changes to the Executive
Summary, as they will require additional writing.
Mr. Meister, Mr. Stannard, Mr. Chapman, Mr. Holland, and Mr. Anderson volunteered to help in redrafting the other
portions of the Executive Summary.
Ms. Throwe acknowledged the Board does not have time for a discussion about the Transmittal Letter. She said the
Letter, in its current state, is too vague. She asked if there were a couple of Board Members who would work with her to
enhance it.
Mr. Zimmer volunteered to help Ms. Throwe.
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Mr. Chu said the draft of the Transmittal Letter currently reads as a description of the process. He suggested the Letter
should be akin to what one would say to the Administrator. He also noted it should reflect the Executive Summary,
which may delay the Board's ability to work on it.
Ms. Throwe agreed Board Members will have to wait for the Executive Summary to take shape before finalizing the
Transmittal Letter.
Mr. Chu said if the five-member team putting together the Executive Summary could provide a redrafted version by
Thursday morning, they could review it as a Board. Otherwise, Board Members will have to hold a subsequent call to
vote on the report.
Ms. Throwe asked Stephanie Sanzone of the EFAB staff if the Board could take a vote on moving forward with the report
at this time.
Ms. Sanzone said her sense is there are too many pieces of the report still pending to hold a final vote today.
Ms. Throwe agreed and said the Board would vote at a later time.
Environmental Finance Centers
Ms. Throwe introduced Khristopher Dodson and Medessa Burian from the EFCs to provide updates on their activities.
Mr. Dodson is the President of the EFC Network and Director of the EFC at Syracuse University in EPA Region 2. Ms.
Burian is the Assistant Director of the EFC at the University of Maryland in EPA Region 3. At the next EFAB meeting,
Martha Shells from the EFC at the University of Southern Maine in EPA Region 1 will attend as the new president of the
Network.
Mr. Dodson thanked the Board for their discussion and provided a summary of what the EFCs do. There are 11 EFCs, one
for every EPA region and another that is not EPA-supported. Mr. Dodson noted the topics the Board is addressing are
well-aligned with the work of the EFCs. The EFCs provide technical assistance. When EFAB writes these reports, it is an
opportunity for EPA to use the EFCs as a vehicle to implement their recommendations. EFCs have knowledge, expertise,
and the relationship with both EFAB and EPA.
Ms. Burian said she was very encouraged by the Board's conversation. She described EFC work as falling into two
buckets. The first bucket is related to education and technical assistance. EFCs communicate actively with their
communities to understand their needs and drivers. Stormwater, for example, can be framed in a lot of different ways
(e.g., local economics, public health, flooding, infrastructure damage, impacts on businesses, urban heat island effects,
green infrastructure). The second bucket deals with resource building and the creation of decision-support tools to serve
a broader audience.
Ms. Throwe acknowledged there are emerging trends around the country for which the EFCs are providing support. As
EFAB considers new charges, she asked where Mr. Dodson and Ms. Burian see these new trends emerging.
Mr. Dodson said they came prepared to talk on behalf of the entire EFC Network. They are starting to look at rural
stormwater needs more, particularly with increasingly severe and episodic rain events that damage transportation
infrastructure and jeopardize water quality. The maintenance of that transportation infrastructure, particularly in rural
areas where the highway department tends to want to get the water out faster, is antithetical to what they want to take
place during these storm events. The EFC Network is also looking at rural stormwater asset management (e.g., ditches,
culverts, streets) as stormwater infrastructure. The EFC out of Michigan Technological University is looking at a "one
infrastructure" approach, treating transportation infrastructure as stormwater infrastructure and vice versa. Another
notable trend is related to small community resiliency. The Network is finding that small, generally rural communities
are hollowing out both demographically and with regards to their infrastructure. Sometimes EFC staff will work with a
community intending to fix its utility and set up an asset management plan, but they then find their first problem is an
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aging demographic; those in the room will not know who is going to be there in 30 years. EFCs have been increasingly
looking at the social and economic status of these communities.
Ms. Burian said affordability and equity are also emerging topics. Her EFC is working with the EFC out of the University of
North Carolina at Chapel Hill on an affordability project that is evaluating household and community affordability
metrics for water systems. They are reviewing case studies of mid-sized communities across the country to look at their
affordability concerns and how they are dealing with them. The Network is also moving towards talking about integrated
water resources management, or a "one water" concept. Ms. Burian noted costs for water services are continuing to
increase. Moving forward, it will be important for the Network to look at these systems and the water cycle hoiistically.
EFCs will need to consider how they can bring about cost savings for communities through an integrated system.
Ms. Downs asked what they mean by mid-sized community.
Ms. Burian said they define mid-sized communities to be 100,000 people or less.
Ms. Downs asked that they consider other urban cities that may not fall in that population-based category. She noted
the poverty rate is so high in New Orleans that she would think the city's affordability issue rivals that of some mid-sized
communities.
Ms. Burian said they would love to expand the communities considered, but she noted that the initiative is EPA-funded
and the agency chose to target cities of that specific scale.
Mr. Dodson said he would send Ms. Downs a report for the City of Buffalo. While Buffalo also has a smaller population
than New Orleans, it may be somewhat relevant.
Mr. Zimmer said his bank would have a huge interest in the studies the EFCs are conducting regarding stormwater and
transportation projects. He asked where he could find that information.
Mr. Dodson said the short answer would be for Mr. Zimmer to reach out to him personally, or the current president of
the Network. Ms. Throwe also has strong ties to the EFC Network. One of Mr. Dodson's desires would be for EFC
representatives to speak with the Board more often. He finds when listening to the discussions Board Members are
having, he wants to be able to have them directly call him or vice versa.
Ms. Throwe emphasized how many reports and studies the Network has produced. She confirmed the Network website
would also show the latest president and their contact information.
Mr. Dodson said the Board can also look at the Water Finance Clearinghouse, where the Network posts a lot of its
resources.
Mr. Chu said the different EFC websites are very well-done and listed in one place by EPA. The question is whether the
current studies the EFCs are working on are posted there. In those cases, one would need to contact the EFCs directly.
Mr. Anderson asked how the Board could take better advantage of the resources that the EFCs provide and whether the
EFCs are at capacity.
Mr. Dodson said the EFCs are almost never at capacity. He noted some of the EFCs are multi-million-dollar centers and
almost all are at universities where they can rely on undergraduate and graduate students for cost-effective labor.
Mr. Anderson asked what kinds of schools the EFCs are affiliated with (e.g., business schools, technical schools, science
schools).
Mr. Dodson said it varies. He, for example, is in the engineering school. Most staff at the EFCs are policy people.
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Ms. Burian added EFCs can work in two different respects. They can work on top-down initiatives, helping translate big
ideas down to the community level, or they can communicate community-level concerns and issues back up.
Mr. Dodson said one thing that differentiates EFCs from other technical assistance providers like Rural Community
Assistance Partnership (RCAP) organizations or Rural Water Associations (RWA) is that they focus almost exclusively on
the managerial and financial aspects of infrastructure and community and utility operations.
Mr. Henifin asked how communities access EFC resources.
Mr. Dodson said the EFCs do a lot of trainings and workshops to bring people into the room. There is a national small
systems project in which the whole Network participates. Through that one program, EFCs do more than 100 training
workshops a year across the country. Other centers will then do their own trainings as well, sometimes working with
partners like AWWA, after which participants will often follow up for technical assistance.
Ms. Burian provided two examples from the EFC at the University of Maryland. Through its Sustainable Maryland
Certified program, the EFC connects with municipalities across the state to form green teams and take them through a
set of sustainability actions. The EFC also has the Municipal Online Stormwater Training Center, a region-wide, growing
center that provides stormwater education and training to local government audiences.
Mr. Stannard noted the EFCs' funding comes from EPA annually. He asked if they are able to augment that funding with
other research grants.
Mr. Dodson said the money EFCs receive from EPA, which they refer to as "core money," varies in percentage of their
budget. That variability means there is a freeboard between what they receive annually from EPA and what they could
receive should EFAB request EFC support on a project, for example. He explained the EFCs are not an EPA-funded
program; they are a program set up by the EPA. They also use their core money to leverage other funding programs. A
few EFCs receive a lot of USDA money. His EFC has a grant from the National Oceanic and Atmospheric Administration
(NOAA) this year. Sometimes an EFC will receive private foundation money or enter into a contract with a specific
community.
Mr. Chu said the arrangement is similar to another set of centers funded by EPA that focuses on pediatrics and children's
health. He said EPA cannot fully fund the EFCs as EPA centers; rather, EPA provides a nominal level of seed funding to
start the infrastructure. The idea is for EFCs to either grow or provide services in their EPA Region. In Region 7, for
example, EPA gives the EFC money for a variety of projects (e.g., a recent waste-to-gas project for water infrastructure).
States may also give money for projects. Different EFCs have different sets of expertise too. For example, the EFC in
Region 10 does a lot of work with tribes in Alaska.
Ms. Throwe said the EFCs are amazingly economical and effective, working at the local level where change occurs.
Mr. Dodson said workforce development is also an emerging trend for the EFCs. WEF and AWWA had their
Transformative Issues Symposium in August in D.C. focused on water workforce. At least two EFCs, Wichita State
University in EPA Region 7 and Syracuse University in EPA Region 2, have developed "Work in Water" programs. Mr.
Dodson noted the EFCs leverage one another's resources. The EFC at Wichita State received a grant to create a type of
internship program. It then gave its application to the EFC at Syracuse University, who submitted it and replicated the
program in New York and Puerto Rico. The EFC at Syracuse University and the EFC at the University of Southern Maine
also have grants to conduct analyses pertaining to coastal resilience, specifically the economic impact of recurring
flooding at the community level. For example, what happens when the marina goes out of business and people stop
visiting and spending money? A community may not have the money to construct a seawall around the entire area but
investing in certain areas can increase their resilience.
Ms. Burian added the EFCs see their core funding as innovation funding. It allows them to not only seek and leverage
other funding sources, but also visit conferences and communities to seek new and better ways of serving those
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communities. She noted there is a fairly high cap on their funding, which allows EPA to give funds without having to
compete them. She said it can be an efficient and timely way to get work done.
Mr. Crooks said he sees the EFCs' work as amazing. He commended their capacity and ability to make an impact in the
industry. He said he is concerned the EFCs fly under the radar for a lot of people. He asked, when Mr. Dodson and Ms.
Burian speculate about the future of the EFC Network, what is on their wish list for how to connect with small utility
entities who are struggling with issues they can support.
Mr. Dodson said EFCs are beginning to do more outreach now, both on their own and through EPA. There was an EFC
Day at EPA last June; while that was not marketing to EFC audiences, it helped market the EFCs to EPA staff so they may
better utilize them and promote them to others. They also market themselves through their nationwide small systems
project and training workshops. He acknowledged that the process of promoting the EFCs is expensive. A year and a half
ago, they had marketing one-pagers drafted with the support of EPA and Cadmus. He said it is something of a never-
ending process, and he feels they could do better. If he had a wish list, it would be for their partners to have the tools
they need to promote the EFCs.
Ms. Throwe suggested there may be a way for Board Members to be better acquainted with specific projects in which
the EFCs are involved. For example, the Board could invite EFC representatives back to future meetings and highlight at
each meeting one or two EFCs to talk specifically about their work. She asked if the Board would be interested in that
idea.
Mr. Crooks agreed with regularly incorporating the EFCs into the Board's agendas. He asked if the Board has an internal
process when taking on new charges to see whether the EFCs have conducted work on the topic or studied the issue.
Mr. Dodson said he is not aware of such a process. EFCs used to serve as expert witness to the charges, and every charge
would have at least one if not several EFCs associated with it. In the past, EFCs have also served as the workforce for
some of these charges, helping with research and writing. He said engaging with the EFCs during the charge process
would be a good idea.
Mr. Chu said Mr. Crooks' question pertains to the standard operating procedure (SOP) for how the Board approaches
charges. The Board could invite EFC representatives in teeing up issues in the same way it does for other experts. He
noted EFCs are not a part of the Board's working groups; as they are such an integral part of the work the Board does
though, he agreed there should be some connection. He said he would see how to make that work. One of the
challenges is the EFCs do not have the money to attend all the Board meetings. EPA would have to find the budget for
EFC representatives to join. He said the primary question is what the Board can do to expand the influence and the
knowledge of the work of the EFCs. He suggested that topic could be something the EFC representatives speak to at the
next meeting.
Ms. Throwe asked if others on the Board supported Mr. Chu's suggestion.
The Board agreed.
Ms. Throwe thanked both Mr. Dodson and Ms. Burian for their attendance and contributions.
Mr. Chu said he has not been in many rooms with such energy and passion for stormwater issues. On behalf of EPA and
the Administrator, he appreciated the work the Board is doing. He acknowledged the Board Members are contributing
their time on a volunteer basis and thanked them for their consistent engagement.
The meeting adjourned at 4:38pm.
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Day 2
Reconvene and Brief DFO Remarks
Mr. Chu welcomed the Board back to the second day of the meeting. He returned to some of the remaining items from
the meeting yesterday. Mr. Chu said he wanted to ensure the Board set aside time to finalize the stormwater task force
recommendations, Executive Summary, and Transmittal Letter, ideally before the end of the day tomorrow. He also
noted there had been some glitches in getting previous EFAB reports posted to the website, which have since been
resolved. The latest EFAB reports do not all have responses from their sponsoring EPA offices; these receiving offices are
working on their responses to EFAB now, and they will be shared and posted when available.
Regarding Board membership, Mr. Chu noted that all Board Members except the Chair are up for renewal or will have
termed out before the August meeting. The membership of the Board at the August meeting is likely to be significantly
different. There are several prospective charges the Board will discuss tomorrow that have been generated by Board
Members. He asked that they keep in mind the changing composition of the Board as they consider new charges.
Ms. Throwe thanked the Board for their hard work and continuing effort. She acknowledged the expectation that the
EFAB reports are uploaded on a timely basis and that the work of the Board is recognized by EPA in a timely matter.
Mr. Zimmer said he noticed the Board spends a lot of time creating incredible work for the public. The Board's work is
then sent to the Administrator. He wanted to discuss the ability of the Board or EPA to promote or share the work of the
Board to get it out to more people in a faster or more efficient way. In his opinion, the work of the Board is sent to the
Administrator and is posted online, but once there, it sits. He wondered how distribution could be improved, be it
through agencies, EFCs, or other entities.
Mr. Chu said it is his job as DFO to work with EPA to make sure the reports from the Board are not only used, but that
their recommendations are answered. With respect to making the reports available to the public, he said they do the
very minimum of putting the documents online. He acknowledged Mr. Zimmer is asking for more than that in the form
of greater outreach and dissemination, something the Board has not discussed or considered. He noted this topic also
relates to the EFCs. EPA has invested a lot in the EFCs, though very few people know about them or what they do. He
said it would be great for the Board to provide some feedback on how EPA could better share and promote its work. Mr.
Chu explained the Board was previously housed in the Office of the Chief Financial Officer before he was DFO. EFAB is
now housed in the Office of Water. When Mr. Chu refers to glitches, he said they are not anyone's fault; rather, there
has been a lot of change in personnel and in how the Agency does the work. He is hopeful these issues have been
resolved and the reports and Agency responses will be made available in a timely manner moving forward. He
suggested Board Members reserve time at this meeting or moving forward to talk in greater depth about the point
raised by Mr. Zimmer.
Ms. Throwe agreed. She said the Board Members would return to the topic should they have time in their agenda for
this meeting.
Thomas Liu, a current consultant and former EFAB member, acknowledged there is a concern in terms of who reads the
Board's work. He suggested EPA track who accesses the EFAB webpage and different documents produced by the Board.
He is also on EPA's mailing list, which notifies people of reports as they come out. He said this email chain may be a
great way to share updates from the Board to both EPA staff and other interested parties.
Mr. Meister noted the Board is looking to amplify the impact of their work product, rather than market it. Board
Members want to determine how to get their work out into their respective streams or areas of influence.
Small Community Environmental Services Resiliency Panel Discussion
Mr. Chu turned to introducing the panel discussion on the agenda. He noted the resiliency of small communities has
been a recurring topic for the Board, including in their work on the Backhaul Alaska project. During the Fall 2019 EFAB
meeting in Kansas City, Mr. Chu committed to sharing with the Board some perspective about what EPA is doing in this
space. This panel has been assembled to discuss a sampling of what EPA programs are doing to address the needs of
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smaller and/or rural communities. Mr. Chu then introduced each of the following panelists and asked them to provide a
description of their work:
Amy Storm, EPA's Office of Brownfields and Land Revitalization
Jacob Burney, EPA's Office of Environmental Justice
Matthew Dalbey, EPA's Office of Community Revitalization
Barbara VanTil, EPA's Office of Enforcement and Compliance Assurance
Al McGartland, EPA's National Center for Environmental Economics
Office of Brownfields and Land Revitalization
Ms. Storm thanked everyone for the invitation. She is the Team Leader of Policy Outreach and Research within the
Office of Brownfields and Land Revitalization. The Office of Brownfields and Land Revitalization has four parts.
1. The first part is the Competitive Grant Program, where the Office spends a lot of its money from Congress. The
Competitive Grant Program provides different types of grants for assessing brownfields, cleaning up
brownfields, and providing job opportunities.
2. The second part is noncompetitive, in which the Office gives an allocation to states/tribes every year to support
their brownfield programs; as the Office is not regulatory, the states/tribes provide a lot of the oversight.
3. The third part is to help explain liability and the different components of being liable under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA). Ms. Storm noted the Office does not
currently have a lot of new work going on in this area.
4. The fourth part is the smaller and noncompetitive Land Revitalization Program. The Office offers communities
technical assistance, with the projects coming by way of regional staff who have been working with communities
trying to redevelop. Site design and preparation make up a lot of the technical assistance for which the Office
receives requests. In the last year, Office staff have been putting together trainings and webinars to help explain
the redevelopment process for contaminated properties. The Office's approach is from the perspective of a
developer and what that means in terms of helping communities leverage resources. Ms. Storm noted the Office
does not always receive many applications from small communities, as the capacity to manage a grant can be a
significant barrier. When small communities are able to apply, they do fairly well in their competition with
success rates on par with larger communities. Ms. Stone said the Office sees a heavy reliance of small
communities on states. The Office has also seen success with different types of coalitions that do the
assessment on behalf of small communities.
The Office also has a noncompetitive program called Targeted Brownfields Assessments in which EPA sends contractors
to conduct an environmental assessment for a community. Communities can participate through reaching out to their
EPA Region.
The Office also provides technical assistance not unique to small communities. For example, there are different
organizations like the Center for Creative Land Recycling in California that receive grants from the Office. The Office's job
under that grant is to work with communities with brownfield questions and challenges. Other types of technical
assistance are in place with Groundwork USA, whose sole focus is to help communities work through equitable
development and environmental justice.
Mr. Zimmer asked who the regional contacts are within the Office of Brownfields and Land Revitalization and who he
should speak to for Region 2.
Ms. Storm said Terry Wesley is the Brownfield Section Chief in Region 2. Mr. Zimmer could also speak to Sadira Robles,
the Land Revitalization Coordinator for Region 2.
Mr. Chu said he would be happy to provide the Board with the list of contacts for each EPA Region.
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Office of Environmental Justice
Mr. Burney, with the Office of Environmental Justice, provided a review of the Environmental Justice Grants Program,
the main vehicle for providing environmental justice support to small communities. The definition of environmental
justice at EPA is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or
income with respect to the development, implementation, and enforcement of environmental laws, regulations, and
policies. There are two main environmental justice funding opportunities that the EPA has.
1. The Environmental Justice Small Grants Program. These are $30,000 grants awarded every other year to at least
40 projects, usually about four in each EPA Region, for smaller organizations, communities, and tribes. The grant
programs are catalytic in nature. The motto of this program is that small funds can lead to big impacts, and
these grants are designed to help smaller communities and grassroots organizations address targeted
environmental issues. In 2017, the Office focused on rural and/or under-developed states (e.g., Arkansas, West
Virginia, Indiana, Utah, Kentucky). Of the 36 projects awarded in 2017, 64 percent went to those states. An
example of one project is in Clinton County, Iowa, where there are disproportionately more elderly than in other
Iowa counties. A study in 2015 found that pharmacies prescribe 25 percent more opioids to residents of Clinton
County than other counties in Iowa. For the elderly population, it is often easier to dispose of extra medication
down the toilet, and it was found to be impacting the water. Through the Environmental Justice Small Grants
Program, an organization in Clinton County was able to, among other things, start medicine take-back programs
and awareness campaigns.
2. The Environmental Justice Collaborative Problem-Solving Opportunity. This program provides 10 projects, one
per EPA Region, with $120,000 over two years. The program focuses on building stakeholder diversity. The
environmental issues being addressed are of a nature that will reach resolution 5-10 years down the road.
Office of Community Revitalization
Mr. Dalbey is the Director of the Office of Community Revitalization within the Office of Policy. The Office was formed
out of the Brownfields Policy Office in the Clinton Administration to support development beneficial for the economy,
the environment, and human health. From the 1990s through the Great Recession, most of the Office's work was
helping growing communities adjust their growth to reuse existing properties and infrastructure. From the federal
perspective, this initiative was important because (1) better development patterns result in better environmental
quality, and (2) the federal government spends a lot of money on infrastructure and development.
The Office of Community Revitalization now does a lot of outreach and communication work and recently started
providing technical assistance. After the recession, Office staff recognized many communities were not developing
because the basis of their economies had disappeared. A lot of legacy environmental challenges faced by communities
are not due to science but rather the loss of industries that had been the economic drivers in the community. One way
to address this is to help communities reinvent themselves. Mr. Dalbey spent a lot of time working with Strong Cities,
Strong Communities, a program in which the federal government brought catalytic investments to communities to help
them develop and execute their economic strategies. At that time, Mr. Dalbey said he came across a quote by Wallace
Stevens, "It is necessary to any originality to have the courage to be an amateur." His office, mainly made up of urban
planners, began to delve into economic policy.
Shortly thereafter, Appalachian communities asked for the Office's support. The Office began to create programs to help
communities identify economic drivers to revitalize main streets and reuse existing infrastructure. In Appalachia, Local
Food, Local Places became the flagship small community program to promote economic development, preserve rural
lands, and increase access to locally grown food. Since 2014, the program has been in over 150 local communities.
Another program the Office started around that time was Cool and Connected, built around the federal government's
investment into broadband. The program helps rural communities use broadband service to revitalize small-town main
streets. The Office also recently started Recreation Economy for Rural Communities, a planning assistance program to
help communities revitalize their main streets through outdoor activities.
Mr. Dalbey noted, in rural America, what came from the land could once be transported by railroad and give economic
purpose to towns. He said the question now is how those economies can be harnessed to revive existing properties.
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Since 2005, the Office of Community Revitalization has worked with 600 communities across the country. Since 2017,
the Office has worked with 150 rural communities, usually in partnership with USDA. Office staff are also working with
USDA to map where their investments are going. They overlaid Opportunity Zones with their investments and found that
around 20% of USDA investments are going into the actual towns, with 80% going to highways. To make catalytic
investments that support economic development and quality of life in rural America, it is more advantageous to make
those investments where there are existing main streets, downtowns, and properties. The Office of Community
Revitalization can work with USDA to make better investment decisions for better environmental and community
outcomes.
Office of Enforcement and Compliance Assurance
Ms. VanTil is in the Office of Compliance, where her colleagues have been looking into what clean water and drinking
water compliance tools they can provide. A lot of drinking water and wastewater systems have a hard time achieving
and sustaining compliance. There are a number of root causes for this noncompliance, especially for small systems. They
include aging infrastructure, declining rate bases from population loss or inadequate rate structures, and workforce
shortages. As experienced operators retire, it is very difficult to bring in and retain new people. In many cases, these
systems are remote or in rural areas that cannot sustain a competitive pay level. There may also be managers and
operators without the required skills or knowledge. EPA is always promoting asset management and degradation
prevention of old systems. Sometimes the challenge can be as simple as not understanding the regulations or the
technology.
The rate of noncompliance for small systems is much higher than with larger systems, and this problem is magnified in
drinking water systems. When looking at the 150,000 public water supply systems nationwide - i.e., privately or publicly
owned systems providing water for human consumption - 90% are small systems and 93% of serious violators are small
systems. The Office of Compliance introduced a circuit-rider program to provide hands-on support and better
understand the barriers to compliance. Circuit-riders are part consultant and part trainer. They visit systems multiple
times, assisting with technical, managerial, and financial issues. The Office of Compliance is also trying to promote
partnerships and the development of local support networks. While this circuit-rider program is just starting, it is meant
to complement other existing circuit-rider programs to support water infrastructure.
National Center for Environmental Economics
Mr. McGartland noted the other panelists are on the "retail" side, while he is on the "wholesale" side in the Office of
Policy. His main objective is quality science for quality decisions. Through benefit-cost analyses and economic impact
analyses, he aims to inform decisionmakers about the consequences of their actions. He noted the United States is
making large environmental investments, and it is important to get the best possible return on those investments. With
the Waters of the United States rule, the Administration talked about a new environmental federalism with state and
local partnerships. This shift has created an opportunity for EPA to further engage with partners in water and other
media on technical assistance and economics. For example, with the recent Lead and Copper Rule Revisions, Mr.
McGartland is working with behavioral economists on his staff to gather more information for utilities on how to design
cost-effective lead service line replacements. President Trump also signed the Foundations for Evidence Based Policy
Making Act into law a year ago, which ups the ante on trying to bring evidence to bear on the operation of programs and
policies. Mr. McGartland's Office submits a "learning agenda" to the Office of Management and Budget on the key policy
questions to answer. His Office's staff then need to provide scientific and economic evidence in response to those
issues. He noted the operation of many of the regulations and programs in small communities will be an issue in that
context. Lastly, the Unfunded Mandates Reform Act requires EPA and other regulatory agencies to look at impacts to
small businesses and small governments. If costs go over certain triggers, staff will engage in consultations or panels to
hash out better solutions to get both manageable costs and a win for the environment. He noted the consultations with
small governments are more common than those with small businesses.
The National Center for Environmental Economics also routinely conducts affordability analyses. Mr. McGartland noted
EPA tends to focus on the affordability of the rule they are considering, rather than its cumulative costs. Mr.
McGartland's Office is also spending a lot of time on incidence analyses to see who is paying for these regulations. He
said EPA regulations can be quite regressive. Low-income households, for example, spend a much higher percentage of
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their income on power, and EPA must be cognizant of that on regulations moving forward. These analyses can have big
effects. For example, arsenic in drinking water was often a problem in small and low-income communities. It was
estimated the cost could be as high as $500 per household per year. A big discussion ensued, and EPA mobilized to
perfect and reduce costs of technologies and help provide funding assistance in other ways. When the rule went
forward, it became quite controversial. Mr. McGartland noted the large systems enjoyed economies of scale, so the cost
per household was affordable and quite low. EPA seemed legally or by policy to want the same standard for everyone.
The Office of Policy is also involved with the environmental impact statements required through the National
Environmental Policy Act (NEPA) when, for example, the Army Corps is looking to invest in infrastructure. Office staff
developed a handbook on land clean-up and reuse. They invited a group of academic economists to EPA for two days to
discuss how to quantify the benefits of brownfields, superfund programs, and state clean-up programs. Outside of
impacting health and land productivity, they talked about how these programs could also lead to agglomeration effects.
For big areas like Silicon Valley, the cost savings that accrue from these agglomeration effects are easier to see;
industries co-locate because of savings like reduced transportation costs, a shared labor pool, and positive information
exchange. Those same benefits are possible with communities. Once there is some development, the literature has
shown it is more likely for other investment to take place. Mr. McGartland noted agglomeration effects seem to be more
pronounced and likely in cities rather than rural areas, which may be one of the challenges they face. Staff also worked
with the Office of Environmental Justice on providing technical guidance on how to assess, using economics and science,
the environmental justice issues associated with regulations, allowing them to get involved in local community issues.
Mr. Chu thanked everyone for sharing their corners of EPA in which they touch on the issues facing small and rural
communities. He noted while there is not one organization at EPA dedicated to this area, there is a cross-section of EPA
staff working in it.
Mr. Chu opened the floor to questions and comments. He hoped this discussion would also help inform the Board in its
decisions to pursue future charges.
Ms. Throwe thanked everyone. She asked Ms. VanTil who the circuit-riders are (e.g., EPA staff, contractors).
Ms. VanTil said they have set up contracts. They work with regions and states to identify communities who are most in
need and then send people accordingly.
Mr. Meister thanked Mr. McGartland for his contributions. He asked if Mr. McGartland could elaborate on the role of
behavioral economics in his office.
Mr. McGartland said behavioral economics is gaining a lot of traction in his profession. Of his staff of 30 PhDs, he has
two members who focus on behavioral economics issues. They did not start in behavioral economics; it has been a
learning curve. He said he sees a lot of potential for what behavioral economics could bring to EPA.
Mr. Henifin said he works with a large utility in southeast Virginia where he engages with both large urban and small
rural areas. He said the idea of a circuit-rider sounds great, but he wondered if it is sustainable. He finds pouring
resources into these struggling communities seems to counter a long-term solution to the problem.
Mr. Dalbey acknowledged there are a lot of resources that go into communities without economies. He finds it
important to look back on history. In the last 150 years, pre-New Deal, if an economy left, then the community
disappeared. The New Deal led to an investment in infrastructure still important today. It also created a set of policies
that treated symptoms and not the root causes. He noted there are still not policies in place that treat the root cause of
economic decline in many places. His Office is trying, in a retail-type of way, to help build the capacity for communities
to recognize the importance of reinventing themselves. From an environmental perspective, there is some sense that if
the environment is cleaned up, economic growth will come. The Office of Community Revitalization has been afforded
the opportunity to talk to other agencies working in economic development. He said there are other ways to protect the
environment beyond regulation. For example, in New York, the animals in the Bronx Zoo started dying because of the
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water they drank from the Bronx River. New York City recognized the need to clean up the river and protect the
shoreline, resulting in the building of the Bronx River Parkway.
Ms. VanTil thanked Mr. Henifin for his question. She said her Office has a small amount of money it is putting into this
program. Staff are trying to learn from the experiences of other offices in EPA to figure out what is keeping people from
complying and applying those lessons more broadly. She noted some things will change the landscape. For example,
there are provisions within AWIA where states will need to develop the ability to mandate some level of consolidation
for water systems. At a certain point, it will not make economic sense to have utility operators work independently
when there are benefits from economies of scale.
Eric Rothstein thanked the panelists for their attendance and thanked Mr. Chu and Ms. Throwe for setting up the
discussion. He explained he has been in the redevelopment business for over 20 years, and a lot of the issues faced by
the Board pertain to rural communities. He finds there are bigger policy implications, particularly with who is going to
deal with these issues as these economies disappear. He offered a couple of observations on the issue of reinvention
and why it is critical. He said a lot of these rural communities existed for logistical circumstances that no longer exist.
There is a belief that if these areas are cleaned up, people will come. In his opinion, people will come regardless of the
environmental condition; it is the economy, the market, and the labor pool. He said one of the issues not yet covered is
how to attract capital. Programs like the ones described by the panelists are in the minority, but they are hugely
valuable moving ahead. He asked what opportunities they see for the Board to help with figuring out how to attract that
capital (e.g., greater certainty of regulation, a larger kick-starter element of funding, a less piecemeal approach).
Ms. Storm noted communities are always struggling with how to attract capital. Her Office has been trying to explain to
communities the value of planning, but they are continuously thinking about what a community can do to prepare
themselves to be of interest to a developer or investor. She suggested the Board Members consider, in their collective
experience, what has really made the difference in attracting capital. She asked, "Communities can develop a plan and
assess a brownfield site, but what do investors or developers really want to see?"
Ms. Kim said the main concern for developers and/or investors is risk. A developer risks a lot of soft costs. These soft
costs result in a scary amount of risk because the developer must pay for consultants, architects, and engineers to see if
the project is even feasible. Any grant that can relieve capital risk is helpful. She said the second piece is the need for a
one-stop shop. She explained she would not want to go to the Department of Housing and Urban Development (HUD),
Department of Energy (DOE), or EPA to figure out different grants. The Board has been thinking about developing a
common application across the different agencies that can help pull together a set of grant opportunities and resources.
Mr. Dalbey said the Board could conduct some research into the type of catalytic public investments that could go into a
community to help lower the risk of private sector investment. Does private capital follow DOE investment in a
community? Does it follow USDA Rural Development money? Does it follow the assessment and cleanup of a brownfield
site? Feeding that information back to EPA could help those at the staff level begin talking to other agencies to
understand how investments could lead to capital. The Board could also conduct research on the policy in and around
technical assistance and capacity. For example, grants at a local level could help raise the ability of a community to
rezone.
Mr. McGartland said there are three groups of communities - those that are thriving, those driven by a simple market
and the logistical role they played in a pre-technological economy, and those on the edge. He would ask how EPA could
better identify which communities are which and where retail operations could make a difference.
Ms. Storm emphasized the reality of Ms. Kim's soft cost statement. There are not a lot of federal grants available for soft
costs. She said a key question would be what other sources a community could draw upon to take care of soft costs as
much as possible, as grants can only pay so much.
Mr. Anderson noted the issue Ms. Kim raised about risk and perception of risk. He said one of his challenges is that EPA
and the business community are approaching the problem from two different directions. The business community is
coming at the problem from the perspective that a community is a number with error bars; those error bars define the
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ability to attract capital. He agreed a market study could be a really beneficial pursuit. He also said the Board needs to
look at how these policies work in the context of environmental justice.
Ms. Kim said she would love to see the opportunity zones mapped in geographic information systems (GIS) with the
targeted areas of the grants. The developer will go where the layers of opportunity zones, grants, and tax credits
overlap.
Mr. Burney said there is a publicly accessible environmental justice screening tool, EJSCREEN. Each year it is released and
updated, so such data layering would be possible. In response to the concern of the intersectionality of environmental
justice, he said his Office has tried to integrate sustainability criteria in community action plans. He said the Board, with
its different relationships, could help flesh out templates of what to look for in community action plans where there are
buffers that mitigate soft costs.
Mr. Dalbey said his staff have also layered existing infrastructure over opportunity zones at the census block level in GIS,
which can demonstrate fiscal and economic efficiency and better environmental outcomes.
Ms. VanTil said behavioral economics are a big part of her Office's concern. She noted how people are often willing to
spend more money on their cell phones than their wastewater. It is a question of how to get people to understand and
value the benefit of the service being provided by their utilities, so they receive the rates needed to sustain the system.
She also emphasized the need for something like a clearinghouse where the funding is centralized and accessible to
those who need it. She has found there are sometimes grant programs that people are not aware of that could be
assisting small communities.
Mr. Zimmer addressed his question to Mr. McGartland. He said he represents the infrastructure bank for the SRF
program in New Jersey, and it was interesting as a state to encounter NEPA outside of the SRF program during Hurricane
Sandy. The bank received FEMA and HUD funds and created a disaster SRF program to integrate with them. He noted
the need to standardize the processes to use and leverage these different funds. He explained the frustrating part was
with the environmental reviews and getting different agencies to deal with one another. It took at least six months for
FEMA and EPA to agree that EPA would use FEMA's funds for the SRF program. To improve efficiency, he asked if there
was a way to unify NEPA environmental reviews across the country for the different programs available. If people must
do three different environmental reviews for three different sources of funds, they would sooner go out on their own or
not pursue the project.
Mr. McGartland said the sister office to his is the Office of Federal Activities, which coordinates all the NEPA
environmental reviews. That Office interacts with HUD, Army Corps, and others. The Council on Environmental Quality
and others are leading a charge to better streamline the process. He said he would take this information back with him
and filter a response through Mr. Chu. He acknowledged how, in the wake of Hurricane Sandy, what Mr. Zimmer
experienced would be an obstacle to what they are trying to accomplish.
Mr. Zimmer said to call it frustrating would be an understatement.
Mr. Stannard thanked the panelists for their presentations. He noted his personal concerns with smaller communities,
having grown up and currently living in Kansas. He said he is in the third largest city with a population of 30,000. When
he thinks of small communities, he thinks of the town where his sister taught grade school with a population of 2,500.
Over the last 25 years, the demographics have shown a decline in population and an increase in average age. The once
high percentage of kids have gone to college and have not come back. He said small communities are facing a multi-
faceted challenge. He asked if there is nothing for young people to come back to, whether the momentum is reaching a
point at which the community should be left to age out and deal with what is left afterwards. He asked if the
opportunity zone concept is a way to help pull these issues together to reach a point where some of these communities
can be revitalized and grow in the future.
Mr. Burney said he does think opportunity zones are a viable option that the government is exploring. Back in 2018, the
Office of Environmental Justice focused on rural areas specifically with its collaborative problem-solving grants. Of those
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10 grants, 80% went to rural areas (e.g., central Maine, West Virginia). Summit County, Utah had a project focused on
winter inversions, in which the warm and cold air traps the pollution and results in terrible air quality. A grant in Utah
was used for a wood fireplace and stove exchange program, a volunteer pilot program in which families from the
sparsely populated mountainous region apply for gas and propane inserts. All the collaborative problem-solving
environmental justice grants are designed to sustain and spur coalitions and collaborations to address issues holistically.
Through the Environmental Justice Executive Order of 1994, the Office also includes the Environmental Justice Natural
Resources Defense Council Working Group that is involved in opportunity zones with its sister office, the Office of
Community Revitalization. Mr. Burney noted he and Mr. Dalbey visited Maine to discuss broadband technical assistance
a couple of years ago, and there are still opportunities to try and attract young people back to the area, particularly
through ecotourism.
Mr. Stannard said reinventing communities requires the excitement of political leadership. Instead of focusing on fixing
the problems of today, he wondered if the Board can look ahead and communicate the idea of reinvention. He asked
how the Board can help the leaders in those communities, who are also getting older, think long-term.
Mr. Dalbey said there are a lot of people writing about the point Mr. Stannard is making. Bruce Katz and Jeremy Nowak
have a book called The New Localism which addresses how to grow leadership at the local level to help communities
figure out what they are going to do next. James and Deborah Fallows wrote a book, Our Towns, where they visited
communities that have reinvented themselves. The end of Our Towns offers 11 best practices, including things like being
strategic about investments and connecting to the regional economy rather than the global economy. The community
should consider what its competitive advantage is in building a portion of the materials needed for an industry. He
agreed there is a larger question of how rural communities can be the types of places where young people want to stay.
Opportunity zones can be a leveraging tool for real estate and business projects.
Mr. Dalbey pointed to the role of community champions (e.g., figures in schools or churches) in finding a way to keep
kids interested in where they are born. He also noted how everything is online, so it is critical for as many towns as
possible to have internet access.
Mr. McGartland said, to his understanding, opportunity zones can offer a considerable reduction of capital gains taxes
for those who invest in them for some time. He wondered if there would be agglomeration effects that make
communities more attractive places in the next 10 years.
Ms. Throwe thanked the panelists for their time.
The Board took a 15-minute break.
Status of Stormwater Recommendations
The Board reconvened at 11:17am.
Mr. Chu said the Board would take the extra time to provide a quick update on the status of the recommendations in
the Executive Summary for the Stormwater Task Force report. The objective is to arrive at consensus, so Board Members
do not have to schedule an additional call after the meeting.
Ms. Tarquinio thanked those who stayed up late to complete the recommendations. The Executive Summary has since
been cleaned up and revised. Tomorrow morning the Board will review the changes made according to the discussion
Day 1.
Mr. Chu asked the Board Members to email about any significant issues they have with these recommendations tonight
so they can streamline the conversation tomorrow morning.
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Public Comments on the Stormwater Report
No members of the public registered to give oral comments on the draft stormwater task force report. However, written
comments submitted by the National Ground Water Association (Attachment H) were posted to the EFAB webpage
along with other meeting materials. Mr. Chu noted that he also has just received a document that Chuck Chaitovitz from
the U.S. Chamber of Commerce wanted to share with the Board. Hardcopies of the document were distributed to the
Board and it will be put into the record (Attachment I).
Framing of Backhaul Alaska Session
Ms. Throwe said, before the break, she wanted to set the stage for the Backhaul Alaska activity. The Board will
participate in a consultation, rather than a formal charge.
Mr. Chu said Board Members have been trying to figure out how they approach their charges as a Board. Part of their
SOP is to establish procedures on how they decide to take on projects. They have also talked about charge options that
are not necessarily projects. Gabriela Carvalho with EPA Region 10 came to the last EFAB meeting to discuss follow-up
items and asked for additional, in-person consultation for feedback on the Backhaul Alaska project in its current state.
Mr. Chu said there will not be a written report from this process. It will be a one-time engagement that, if the Board
chooses, could lead to another follow-up request.
Ms. Beecher said the Board should view this opportunity as a case study. She thinks having a roundtable discussion and
offering suggestions could be a complement to formal written reports and a good use of the expertise in the room.
Ms. Throwe noted Ms. Beecher was part of a small group of Board Members who talked through what this consultation
could look like. Mr. Throwe thanked her and those Board Members for their time.
Mr. Zimmer said he is fascinated by this issue. He asked if the Board is allowed by statute to conduct this work if it is not
explicitly through a charge.
Mr. Chu said the Board is allowed to do it. Previous groups have taken on multi-month or multi-year reports. When he
became DFO, he received feedback as to how that approach was working. He said this is less a legal question and more a
question about how the Board wants to provide support to the Administrator. It is a question of how to have the biggest
and most timely impact on the Agency regarding key issues. Mr. Chu noted there is interest in taking on work that is
timelier, and there are various models for doing so.
Ms. Throwe offered the Transit-Oriented Development Study as an example of a different project conducted by EFAB.
The Board came together for a day, brainstormed, and looked at transit-oriented development. She noted the style for
this consultation will be a departure from the way Board Members have worked previously. The Board will break into
three groups to discuss specific sets of questions related to the Backhaul Alaska project and then rotate.
Mr. Meister thanked Mr. Chu and Mr. Zimmer for establishing in their exchange that this method is allowed and
appropriate for the Board. He finds it to be a good use of EFAB public resources. He acknowledged he was very skeptical
about the Backhaul Alaska project and its applicability to EFAB. Even last night, he had conversations where some said it
is a market failure or a funding problem, rather than a financing problem. He said the more time he has spent on the
issue, though, the greater importance it has carried. Ms. Carvalho has presented a more extreme example of all the
challenges Board Members have discussed with regard to shrinking communities, old or undermaintained infrastructure,
and shrinking rate bases. He noted variations of these challenges will come up again and again, and he finds the
advantage to the Board is the opportunity to work through real questions in real time.
The Board broke for lunch at 11:40am.
Backhaul Alaska Consultation on Financing and Governance Options
The Board reconvened at 1:00pm.
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Mr. Chu welcomed the Board back. He explained after the consultation, the Board will send a Notice of Consultation to
the Administrator notifying him of this first-time activity and its consultation on the Backhaul Alaska project at the
request of EPA Region 10. This letter will (1) make the engagement official and carry out the Board's responsibility of
communicating to the Administrator and (2) elevate and expand the knowledge of the work the Board is doing.
Ms. Sanzone noted such consultations and notice of consultations are common across other advisory boards.
Ms. Carvalho thanked everyone for their time and asked her colleagues to introduce themselves.
Tim Hamlin is the Deputy Director of the Office of Management Programs for EPA Region 10. Though he is usually Ms.
Carvalho's boss, he said he has been happy to work for her to support her efforts on the Backhaul Alaska program.
Andrew Crow works at the Cooperative Development Center at the University of Alaska, Anchorage. His involvement
with the Backhaul Alaska project was instigated by a recommendation the Board made to look at cooperatives. He has
met several times with the team and has experience working in rural Alaska. He has lived there for about 30 years and
has worked with many of the government entities involved in the Backhaul Alaska program.
Ms. Carvalho thanked the Board for directing the team towards Mr. Crow.
Ms. Carvalho provided a presentation on Backhaul Alaska (Attachment J). Phase 1 of Backhaul Alaska resulted in the
report submitted to EPA in August 2019. Phase 2 will be the consultation today. The desired outcome of the consultation
is for the Board to provide financial and organizational advice to help ensure that the Backhaul Alaska organization is
both fiscally sound and resilient to financial and other challenges.
In anticipation of this meeting, Ms. Carvalho conducted a webinar on January 30, 2020 to provide a foundation of
information about the stakeholders, services, and conditions on the ground (Attachment K). The briefing resulted in a
handful of key questions that she addressed.
1. What is the role of EPA?
The growth and development of Backhaul Alaska is spearheaded by the Solid Waste Alaska Task Force. EPA has more
of a role in supporting this program through staff and guidance than through funding.
2. Is the solution top down?
The design of the program came from the ground up and was designed to address the liability surrounding packaged
waste. One of EPA's key programs is the Indian General Assistance Program (IGAP). Tribes receive $125,000 a year
for all their environmental management programs. Through this program, tribes communicate their priorities
through environmental plans to better direct their IGAP funds. EPA reviewed 60 of these environmental plans and all
of them listed solid and hazardous waste as a top priority. For many of these communities, backhaul is too expensive
and onerous. About 75% of dump sites in Alaska are within one mile of the village and water sources. These landfills
are unlined and waste burning is not prohibited. Prior to the pilot phase, there were two years of engagement in
which the team spoke with stakeholders on the ground. These interactions informed how this program would be
designed to best meet stakeholder needs.
3. What is the role of native organizations?
The Solid Waste Alaska Task Force works very closely with native organizations. They are partners in providing
services to these communities, and many representatives are serving as regional coordinators in the program. The
Alaska Federation of Natives also passed a resolution in October 2019 acknowledging backhaul as a significant issue.
4. Where are they in the program?
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In 2020, the team is now in the third and final year of the pilot program with 25 communities participating. The Solid
Waste Alaska Task Force will then make decisions as to what happens after the pilot is over to set up a self-
sustaining program.
5. Why are administrative costs high and shipping costs low?
There is a training force that is fundamental to this program. Before the existence of a coordinated training program,
a recycler could receive a shipping container without knowing what they would receive. The recyclers and
transporters were heavily involved in developing the training curriculum to ensure waste is packaged in a safe and
compliant way. The credibility of receiving training certification is what necessitates the higher costs on the ground,
so transporters keep taking waste out of communities. The program overall is not that expensive. Team members
are also seeing economies of scale. Ten years from now, they expect to be serving 162 communities, resulting in a
decrease in per person and per village costs. For the sake of efficiency, she asked the Board not to focus too much
on the details of the program budget.
Ms. Carvalho referred the Board Members to the scenario for Backhaul Alaska contained in their meeting folders
(Attachment L):
Scenario: The Backhaul Alaska program will be fully functional in March of 2021 (one year from now). It is
estimated that operations will cost approximately $1 million per year to backhaul materials initially. At full capacity,
the program will cost about $3.7 million per year. For the purpose of this scenario, assume there will be an
estimated $500,000 available for startup costs, funded through government grants. Also assume that the first two
years need to be funded via grants. Past that, the ongoing funds will be a combination of (1) government funding
(federal, state, tribal, or local grants or appropriations), (2) other funding, such as income from other Backhaul
Alaska services including extended producer responsibility (EPR) support, donations, and/or foundation grants, and
(3) program fees, collected from villages for backhauling services. For purposes of this exercise, assume the
following source funding ratio: 40% government, 50% other funding, 10% program fees.
Unless EFAB recommends differently, the organization will be set up as a non-profit with a Board of Directors with
advisory committees for each stakeholder group. Administration would be centralized with possible contracting/sub-
awarding of all or some program functions.
Ms. Carvalho noted the process for the consultation has been adjusted slightly from the description in the meeting
folders. The Board will be divided into three groups to discuss three focus areas using a set of structured questions.
These focus areas are as follows:
Group 1: Structure
Group 2: Organization and Administration
Group 3: Finance and Sustainability
The Board Members will spend 30 minutes in each group followed by five minutes summarizing what was discussed.
Each group will have a notetaker and someone to relay what was covered by the previous rotation of Board Members.
After the rotations, they will spend 10 minutes on each group sharing key findings and recommendations, followed by a
Board-wide discussion.
Ms. Carvalho directed the Board Members to their respective group locations and said she would keep time throughout
the process.
The Board broke into three groups and rotated between the focus areas participating in breakout group discussions.
Once the Board Members had rotated through groups, they reported out on their discussions.
Backhaul Alaska Report-Outs - Group 1: Structure
Mr. Anderson provided a synopsis of the discussions within Group 1.
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He said there were fairly different opinions across the three groups. A not-for-profit corporate structure was the most
widely agreed upon approach for a variety of reasons. There was little to no discussion around establishing a for-profit
enterprise, as it would be likely to run into regulatory concerns under the public utility commission. There was some
discussion of co-ops, though the groups did not reach a conclusion other than that a co-op would be relatively more
difficult to govern.
The primary reason they landed on the not-for-profit corporate structure was the perceived ability to attract capital
donations. The groups floated the concept of an endowment-funded enterprise with user-fees and tax-revenues being a
minor component of any revenue exercise. It would set up the opportunity to obtain tax revenue and user fees through
an entity that can enforce them. The enterprise would most likely be a subsidiary entity created by the non-profit. There
was some discussion about whether such an enterprise would need to be set up immediately, and they thought the core
entity should be set up now for the long term.
The groups also discussed who the stakeholders are. Should the state be involved, it would probably have some
representative control. It is possible the donors would have representation, and the villages should have some form of
organized representation, though likely not as individual villages given their number and diversity.
There was also discussion on trusts and how they would hold money. The consensus was to favor a non-profit enterprise
over a quasi-government enterprise because of concerns the quasi-government funds could be reallocated. There was
also some discussion about creating an independent non-profit with taxing authority (e.g., business improvement
districts). They wondered about what the duration of the trust would be and how it would maintain its tax-free status
for donors. They talked about using a state-seeded trust and, through time, building up enough income off the initial
seed that the trust gains some greater independence from the state.
Ms. Beecher added a few complementary points. She said there must be a clear statement of mission for this
organization. There are also complexities in representing so many villages, and they will need to find a structure to
ensure the organization is inclusive of their diversity. She noted there is some contrast between fully socialized cost
allocation and more individualized cost allocation. She asked if everyone would pay the same in the interest of equity or
if they would differentiate what they pay for the same reason. She also stressed the importance of putting firewalls
around the funds so they cannot be raided for other purposes. Independent auditors and legal counsel will be very
important as well. She asked if there is space for local jobs as the team introduces private involvement. She said there is
potential for people to contribute to this fund or enterprise in lieu of a tax, penalty, or other enforcement mechanism.
Mr. Anderson said one of the advantages they talked about for the non-profit structure is the possibility of collecting
funds from extended producer responsibility (EPR). As the settling party, the producer would then receive a tax-write off
for the year, and the trust would have the benefit of the funds in hand.
Backhaul Alaska Report-Outs - Group 2: Organization and Administration
Mr. Meister said, in the last rotation, the group opened with the same idea of creating a foundation or trust. This trust
would need a motivating purpose or driving mission beyond taking care of solid waste, like the preservation of a way of
life and of natural Alaska. Group members noted a big idea is what will drive large private contributions to an
investment corpus.
The group members agreed the composition of the board will serve a very important governance purpose, but there
must also be a champion of the charge, someone driving this new entity through to success. They spoke at length about
the different stakeholders that should be a part of a governing board. They recognized the state will want
representation, even if only as a placeholder, but recommended that government members need to be the minority, not
the drivers. Then there can be some subcommittees of outsiders. The functions of the board would include oversight,
policy setting, and strategic planning. The board members would also want to think about who the Executive Director is
and how they monitor outcomes.
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Mr. Zimmer added the board would want to include a member or group of members who are environmentalists. Those
are the people who will help structure the bylaws and ensure there are components in the structure that will outlast the
first round of appointees.
Mr. Meister agreed environmental advocates are very important drivers of successful governance and outcomes. There
was a common vision for a strategic or business plan developed at the board level, so everyone understands what the
mission and outcomes are. The groups discussed how this board will largely be a new entity with new costs. It will have
to be very public-facing, and there must be an expectation for public wins and benchmarks to add to organizational
legitimacy.
Mr. Meister moved to discussing the administrative structure underneath the board. The groups broke up administrative
needs into internal functions and external functions.
Internally, the board would hire an Executive Director. Members of the board would want someone in grant
management who is writing proposals, handling compliance, and documenting the delivery of outcomes.
They would need someone in charge of vendor management. They would need someone for community
engagement (i.e., an outward facing person to respond to inquiries and concerns). They would also need
someone focused on compliance and another person on financial operations.
Externally, there would be people in the following areas: investment management, law, auditing,
information technology, and contract work (e.g., the transportation and recycling service providers).
Once the organization has its mission, board, staff, and vendors, it would want to set up metrics, third-party verification,
oversight, a communication strategy for early wins, a proof of concept, and rewards for early adopters.
Mr. Zimmer said the groups felt as though the program should also focus on incentives rather than punishments. The
groups discussed the need for remedies for noncompliance. One thought was to train locals in the backhaul process to
receive their buy-in. A common feeling across the groups was also that the state has somewhat evaded its responsibility,
and there must be some sort of a central public role for the state in this program.
Backhaul Alaska Report-Outs - Group 3: Finance and Sustainability
Mr. Rothstein said the first thing they discussed was what the actual costs and expenses are that the Backhaul Alaska
team should be concerned about, as they will influence appropriate funding sources. He said they arrived at three types
of expenses, each with different kinds of potential funding sources.
1. Monthly expenses. These expenses would comprise operations and maintenance and would require a
continuing revenue stream likely associated with the users and regular participants of the program.
2. Intermittent expenses. These expenses could include things like grant writing and contract negotiations. They
could be funded through in-kind contributions or a different revenue source than the day-to-day participants of
the program.
3. Capital expenditure costs. The group felt these costs would best be provided through a different revenue source,
though user fees could provide some level of funding.
Everyone agreed on the desirability of some kind of endowment fund as a potentially major revenue source. Backhaul
Alaska would need a good lawyer to properly structure this fund to secure necessary tax breaks. The groups also
acknowledged the program, overall, does not require a significant amount of money, though they did debate the
calculations. They found around $75 million, placed in some sort of endowment or restricted fund, could result in
enough interest earnings to take care of the problem. A very small fee could easily cover the program expenses (e.g., a
dollar on every piece of luggage on a cruise ship, an increase in the cost of a fishing permit, a charge for violating wildlife
protection rules). There was a sense during the discussions that Alaska is reluctant to impose additional fees, but the fee
levels could be so minimal as to slip under the radar and, in the very least, provide some supplemental funding basis.
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The groups also discussed how organizations and corporations may want to claim their provision of support for
protecting environmental areas populated by indigenous populations. Accessing foundations may be a great opportunity
to raise necessary money on a one-time basis. Ms. Sanchez offered the idea of appealing to companies like Amazon,
who are major haulers and shippers, to secure some type of endowment.
The groups also spoke about issues related to EPR and locational and regional disparities. There was the notion that,
regardless of the fee structure, there will likely need to be some form of a sliding scale for affordability. This fee
structure is likely best established and administered at the regional level.
They found next steps would include the following: fuller financial modeling to understand how big the problem is and
alternative ways one could structure the combination of components like user fees and grants, assessing the
opportunity for endowment funding from a variety of different sources, and looking at tax and/or user fee allocations
and the user fee options that might be available.
Ms. Kim added they also discussed the role of positive and negative financial incentives to encourage greater program
success. One idea was to offer awards for communities (e.g., an award for the most waste backhauled). Another idea
was, instead of charging people to dump their waste, to provide something like $20 for every computer brought in to be
recycled.
Ms. Carvalho said she feels all the questions from each section were addressed. Her initial reaction is the discussion and
feedback is going to and already has launched the team's thinking about the future. She said she would take the
summary from the Board and debrief with the Solid Waste Alaska Task Force and the advisory committee.
Ms. Throwe thanked the notetakers and the facilitators from each group. She asked the Board if everything was
captured during the report-out.
The Board agreed.
Ms. Throwe noted if the Board Members have any documents that may support their recommendations or be of use to
Ms. Carvalho, they could provide them to Ms. Sanzone within the next week.
Mr. Hamlin thanked the Board for their time. He said the consultation process reenergized him, and he found their
contributions to be very heartening.
Feedback on Backhaul Alaska Consultation
Ms. Throwe asked the Board for feedback on the process and approach for the Backhaul Alaska consultation.
Mr. Zimmer said, as the Board Members discussed Backhaul Alaska, he found they were talking about a much larger
opportunity. He thinks it would be remiss of them not to encourage the Backhaul Alaska team to think of the process in
setting up this program as a microcosm of the environmental issues Alaska faces. This program could be a template for
preserving Alaska on multiple levels. As the team members set up the governance structures and trust, he encouraged
them not to limit their thinking to backhaul.
Ms. Throwe noted Backhaul Alaska has applicability to other projects the Board is considering as well, making it
beneficial to everyone.
Mr. Chu connected their process as a Board to one idea from their Fall 2019 EFAB meeting in Kansas City to do more of a
deep dive on a project. As Board Members have conversations about their process, this consultation experience could
be a kind of appetizer into what it would look like to do a specific project with an EPA client.
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Mr. Rothstein said Ms. Carvalho and her team are taking on a somewhat impossible task to digest everything that has
been said to them. He wanted to check if the summary would be distributed for the Board's review, as it may not
faithfully represent all the Board Members' thoughts. He offered to do a review for the portion on Group 3 to ensure the
information was fully captured.
Mr. Chu said he would want to discuss the idea with Ms. Carvalho. He commended her for helping the Board in
developing its SOP and for returning to the Board with what EPA did in response to their product. He noted this
consultation was designed as a one-time engagement, and he does not want to ask the Board to take on additional work
informally or as an official charge. Doing so would require an additional FACA process, as the Board would need to be
transparent in sharing its dialogue with the public. He would like to end the engagement here and asked Ms. Carvalho to
share what she and her team develop as a next step. The Board can then discuss how to handle future engagements.
Ms. Carvalho asked if there is a requirement as a part of the consultation to provide a written submittal to EPA.
Ms. Throwe recognized Mr. Rothstein's point that Board Members want to ensure Ms. Carvalho understood the Board's
feedback.
Mr. Rothstein said he does not think it would require any kind of additional posting of materials, but rather a mechanism
to make sure Ms. Carvalho's team has fully documented what was discussed.
Mr. Chu said there will be meeting notes.
Mr. Kaplan said he found the depth of ideas, possible solutions, and awareness of different structures that could address
this problem to be incredibly interesting. He believes the Board as a group has committed a lot of ideas that he hopes
will be helpful for the program. He noted Board Members are being forced to think about raising endowments and
receiving charitable contributions as a solution to what has been a government failure. They should think about this
problem in terms of what government should be doing to support solutions.
Mr. Holland thanked Ms. Carvalho, Mr. Hamlin, and Mr. Crow for preparing a well-run and well-thought-out session. He
said he would lobby for more of these consultation sessions if people are bringing similarly well-organized question and
topic areas. Regarding the output of the process, he said one common theme he saw was that the Backhaul Alaska team
should seek out pro-bono legal counsel as soon as possible to figure out the myriad of tax and structural issues the
Board is not qualified to answer.
Mr. Anderson seconded Mr. Holland and agreed with Mr. Rothstein's point. He said, through this consultation, Board
Members have created institutional knowledge that can be shared with other people. He wondered how they could
memorialize it for Ms. Carvalho's benefit and the Board's future benefit. He said it could be as simple as sending a
transcript around for annotation.
Mr. Chu said Mr. Anderson's idea would be reasonable. He recognized everyone wants an accurate product, even if it is
a summary. He noted the Board is not precluded from sending the Administrator a note to talk about this issue and the
discussion. As an independent board to the Administrator, there is also no reason why the Board cannot make
recommendations for the Administrator to consider.
Mr. Meister said his understanding was the actual working groups from the consultation were outside of the FACA
documentation process. He had thought when they presented the summaries, however, it was being reported as part of
the FACA process.
Ms. Sanzone said the Board never left the FACA environment. The meeting was always open to the public. The issue
with the notetaking was more about having someone sit in all three groups and capture the conversation for the
minutes. The minutes themselves will note the Board broke into groups and then gave report-outs of the discussions,
which will be captured in the minutes.
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Ms. Kim said she found this process to be effective because it was not just about taking information and putting it on
paper. The Board was actively thinking through ideas and interacting. She said a lot of the work they have done as a
Board is compiling rather than thinking and applying their skills.
Ms. Beecher said she found the consultation to be very effective and consistent with her concept of an advisory panel.
She thinks it increased efficiency as well. She said the specific form of the Board's consultation could vary moving
forward, and she noted how much the preparation helped.
Mr. Zimmer asked who was responsible for setting up the three groups.
Ms. Sanzone assigned the Board Members to the groups. She said she tried to balance sectors across the groups and
split up those who had attended the earlier webinar.
Mr. Zimmer said he had the impression they were grouped by common expertise, and he had really enjoyed having all
the brain power come together at the same time.
Ms. Daniel asked if anyone would like to entertain a discussion about whether there should be something in the form of
a letter to EPA to help resolve this issue.
Mr. Chu said if Ms. Daniel is making a proposal to the group then she should do so officially.
Ms. Daniel proposed the Board consider writing something definitive to EPA to recommend a solution for the Backhaul
Alaska program.
Mr. Chapman said his concern with Ms. Daniel's proposition is he did not hear a lot of potentially actionable things EPA
could control. The Board made a lot of observations of things that could be set up within the rights of the state.
Ms. Daniel offered a more specific proposal to ask EPA to fund an endowment like WIFIA to put a sum of money into a
trust fund for Alaska.
Mr. Henifin said Alaska is not a poor state; it is the seventh wealthiest state in the country. He acknowledged it has a
high poverty rate but so does West Virginia and New Jersey. He said he has a hard time seeing the federal government
stepping in to provide support for Alaska when it could find many opportunities to provide similar funding to any other
state.
Ms. Kim said she thinks it is a great idea. She said even $5-10 million would be great for the endowment, as capital
attracts other capital.
Ms. Daniel withdrew her proposal.
Mr. Weiss echoed previous comments that this was a useful process that could be a template for other projects. He
asked if the Board could receive updates on the status of the Backhaul Alaska program.
Ms. Carvalho said she would be happy to return in a year or year and a half to provide feedback.
Ms. Throwe recognized Mr. Liu as an expert consultant on this work. She thanked him for his research and preparation.
Mr. Liu noted he strongly recruited Ms. Throwe to join the previous EFAB workgroup that looked at Backhaul Alaska and
thanked her for her support. He also thanked the Backhaul Alaska attendees and each of the Board Members. He
recognized this topic area was out of everyone's area of expertise, and he said the discussion reflected the depth of their
knowledge and ability to transfer it. He also noted one of the goals of the Board is the active participation of all parties;
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with perhaps with the exception of the discussion of the Stormwater Task Force report, this consultation was one of the
only cases where everyone was actively engaged.
Ms. Throwe agreed. She said she has never seen this level of engagement and suggested it is because Board Members
are truly invested and passionate in the product they are delivering.
Mr. Chu said he has only been with EFAB for a couple of years, but he recognized there was a real consideration at this
meeting of the struggles EPA has in supporting smaller, rural communities. He suspected the challenges of Backhaul
Alaska will continue in other arenas. He also noted the approach the Board has taken today may start to come into focus
as they begin to take on new charges. He said Ms. Daniel's motion for an EFAB recommendation is the kind of thing he
would encourage the Board to do in the future to suggest ideas for EPA.
Mr. Kaplan thanked Mr. Chu and Ms. Daniel for encouraging him to think harder about his thoughts on this issue. While
he respects the work done by the Backhaul Alaska team and wishes them success in their efforts, he stressed there is a
failure of government. He noted he has not fully thought out what the response of the Board should be but directing
responsibility to the state and native entities to be better stewards of their environment is of some import to him. He
said they should be supporting direct government and community action.
Mr. Meister said the consensus appears to be that this process was a positive experience for the Board and a productive
use of time and expertise. He finds it would merit at least a summary of the report-out recommendations in a Notice of
Consultation letter to the Administrator. Otherwise, Mr. Chu would send a brief Notice of Consultation, and the
Administrator would not have any context or understanding as to what a positive break from past practice this process
was.
Mr. Chapman agreed and said he hopes it will lead to success for Region 10. He said he cannot wait to hear back a year
from now about what Backhaul Alaska has done. He thinks the Board should hold themselves accountable on a
performance and outcome basis.
Mr. Chu said the Board could easily summarize a few points in their Notice of Consultation. He noted everyone is
interested in some kind of summary based on the feedback he is hearing.
Ms. Throwe confirmed no one was registered for public comment.
Mr. Chu transitioned to discussing the agenda for tomorrow. The Board will do two things. First, they will arrive at some
consensus on the Stormwater Task Force recommendations in the Executive Summary. He noted the recommendations
are in their verbatim form in the Executive Summary, so approving them is approving the way they are presented in the
body of the document as well. Second, the Board will discuss the Transmittal Letter. Mr. Chu said this Letter is probably
the most important document. The Board will have to agree about the major elements that will be in the Letter for Ms.
Throwe to then prepare and send it to the Administrator.
Ms. Throwe asked for feedback on what the Board would like to see in the Transmittal Letter. She said she does not
want it to describe process but rather to function as a summary of top-line recommendations.
Mr. Chu reiterated if the Board is unable to accomplish these tasks tomorrow, they will have to hold another public
teleconference. Holding another call will require posting another Federal Register notice, pushing back the delivery of
the product into March. The first time the Board could have a call would be the week of March 9. He said all the edits on
the Executive Summary should be reflected in the document Mr. Holland will circulate digitally tonight. He is hopeful
there will only be minor edits to the Executive Summary, and most of the discussion will be focused on the Transmittal
Letter.
Ms. Sanzone said Mr. Holland should send the document to Mr. Chu first, as the Board is currently in a public process.
Mr. Chu can then distribute the document to the Board Members. Mr. Chu adjourned the meeting at 4:53pm.
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Day 3
Mr. Chu welcomed the Board to the third morning of the EFAB meetings. He noted how impressed he is by the Board's
continued energy and engagement.
Stormwater Task Force Report - Executive Summary
Ms. Throwe directed the Board's attention to the Executive Summary of the Stormwater Task Force report. She thanked
Mr. Holland for his work last night in revising it. She said she found it very basic when rereading it, but the Board needs
to start with introductory language and definitions to explain stormwater for those unfamiliar.
Ms. Kim said she has minor comments. She said she would like to include a sentence that introduces the two major
recommendations: appropriate new federal stormwater funding and appropriate funds dedicated to stormwater
education and technical assistance. That way, if the reader does not get past the first page, they will see it.
Mr. Holland thanked the Board for allowing him to redraft the Executive Summary. He said he tried to stay faithful to the
document and refrained from introducing drastic changes. Now that the Board has reconvened, he would like to
propose some major edits. He said he finds Section 1.2 and Section 1.3 to be fairly redundant, and he suggested they be
deleted. From the last sentence of Section 1.0, the Executive Summary would then go into the recommendations in
Section 1.4. Section 1.0 directly preceding the recommendations would also resolve Ms. Kim's concern. The last piece of
the Executive Summary would then be the reiteration of the charge.
Ms. Throwe asked if the Board agreed to Mr. Holland's proposed change in structure.
All but Mr. Rothstein agreed.
Mr. Rothstein explained he does not agree because of the importance of the charge. He said he does not have a
significant problem with the charge being placed at the bottom, but he feels it is the "why" that frames what follows. He
said he could accept this proposed change, though, considering the consensus of the Board.
Ms. Kim asked if the Executive Summary could specify what the "$133 billion in assistance" is for. Right now, she
interprets the figure as being all for stormwater financing, which is not the case.
Ms. Lemoine said the Executive Summary also needs to cite where the figures for $133 billion in assistance and 1,600 of
the 7,550 permitted stormwater entities are from. If the Board cites the information, it will be clearer.
Ms. Daniel agreed with Ms. Kim. She suggested revising the second sentence in the third paragraph to read, "...with
dedicated sources of funding that facilitate access to capital." She stressed what is missing from stormwater
management is sources of funding to help acquire needed capital. In response to Ms. Kim, she suggested the next
sentence then read, "Cumulatively, clean water state revolving programs have provided $133 billion in assistance for
drinking water and wastewater projects."
Ms. Tarquinio noted the assistance was just for wastewater projects.
Mr. Zimmer asked to include the year 1985 to the sentence, so a reader understands the period over which the $133
billion was provided.
Ms. Daniel said the Executive Summary should also note how the pursuit of dedicated revenue sources is faced with the
headwinds of affordability and political will. She does not want the gap to be dismissed as something for which utilities
could easily raise their own money.
Mr. Chu provided a comment on behalf of Ms. Downs, who was not in attendance. She wrote the Board should change
the use of stormwater utilities as an example in Section 1.2 to stormwater fees and cite the 90% figure.
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Mr. Holland noted her comments no longer apply, as the Board is striking Section 1.2.
Ms. Daniel noted the Board is avoiding the topic of climate change, and she said she is comfortable with that decision.
The Executive Summary does cite statistics on the increasing number of significant rain events as driving an urgency to
address stormwater. She is wondering if the Board should insert a sentence that better recognizes this urgency, so
Congress cannot ignore it.
Ms. Throwe agreed.
Mr. Stannard said the Executive Summary starts with a focus on the pollution effects of stormwater and water quality
impacts, but it does not make a strong statement with regards to flooding caused by stormwater runoff. He said, for
many, flooding is the driver for stormwater management with pollution being a subset of that.
Ms. Throwe noted this report addresses both water quality and quantity, and Mr. Stannard's contribution connects to
Ms. Daniel's point about increased rain events.
Ms. Beecher said the last sentence in the third paragraph lists the following dedicated revenue sources: stormwater user
fees, stormwater utilities, taxes, and established drainage districts. She noted this sentence conflates revenue sources
and structural opportunities. Stormwater utilities and drainage districts are structures, and stormwater user fees and
taxes are revenue sources. She reiterated there is a ratepayer pocket and a taxpayer pocket. The other terms are ways
to structure and provide the service. She suggested the Board rephrase that portion of the sentence to read, "dedicated
stormwater management sources including user fees and taxes."
Mr. Meister echoed Ms. Beecher. He noted taxpayers and ratepayers are often the same people. He also said, with 2020
being the 50th anniversary of U.S. EPA, one of the triumphs of the last 50 years has been addressing point-source
pollutants for water quality. He said the next challenge is stormwater which includes and helps to trigger flooding. He
said the Board can work into one of the sentences of the Executive Summary that this report can build upon the
organizational successes of the federal statute and EPA.
Ms. Beecher appreciated Mr. Meister's point. She said taxpayers and ratepayers can and might be the same person, but
one of the struggles is those footprints do not always match. Tax instruments and user fee instruments can also have
very different impacts on household affordability.
Mr. Rothstein said his concern has been there are many municipalities who recognize it would be a good idea to have a
stormwater fee of some kind, but they are daunted by the potential of continuing legal challenges. In a number of
places, municipalities have implemented stormwater user fees and are spending all their time in court defending them.
He wondered if the Board could incorporate the need to provide technical assistance and resources to help states
navigate legal challenges.
Ms. Throwe noted the issue of legal challenges faced by municipalities is not quite captured in the report or its
recommendations.
Mr. Henifin said the Task Force Members intended to address it in the second recommendation. He suggested the Board
insert a piece about legal defense into that language.
Mr. Rothstein agreed. He said only a couple of words are needed about how legal defensibility is a part of sustainable
funding.
Ms. Kim asked to change the structure of the two recommendation categories so the second also leads with an action
verb. Instead of "New federal stormwater funding," it would be "Allocate new federal stormwater funding." She also
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proposed, for the first recommendation about developing a construction grant program, the inclusion of soft costs
associated with construction. She recognized this is a substantive addition.
Ms. Throwe said the Board Members should discuss the inclusion of soft costs, as they spoke about it yesterday, but it is
not currently explicit in the report or the recommendations.
Mr. Crooks suggested the Board revise the lead-in to the recommendation, so it reads, "Federal grants, loans, and new
programs are needed to fund critical stormwater infrastructure and early state development of those resources."
Ms. Throwe asked if Congress would understand Ms. Kim's point on soft costs. She wondered if it is explicit enough.
Ms. Lemoine said the Board could add a footnote that explains what soft costs comprise.
Mr. Henifin said he did not necessarily like the addition of the footnote. He noted this recommendation needs the
further explanation provided in Section Three where it is detailed how this construction grant program would differ from
those that come before it. He said the Board Members need to ensure they do not pile all the information into this short
Executive Summary. Section Three is where the soft cost inclusion should go.
Mr. Weiss agreed. He suggested for the first recommendation to use the language "to develop a new and enhanced
stormwater construction grant program." There are a lot of things in Section Three, and he does not want Congress to
think the Board is proposing a return to the old construction grant program.
Mr. Zimmer suggested Board Members insert a parenthetical to "see Section Three" so they are telling the reader there
is more information later in the report.
Mr. Holland suggested including a preamble to the entire recommendation section explicitly stating there are detailed
versions of the recommendations in Section Three.
The Board agreed with Mr. Holland's suggestion.
Ms. Kim asked if the Board would want to ask Congress to fund technology development.
Mr. Holland disagreed.
Mr. Weiss wondered if, for the third recommendation in Section Three, the Board should move the parenthetical up into
the introductory paragraph so it reads, "the need for increased federal investments in stormwater infrastructure (with
no offsets to other programs)." This parenthetical could also apply to all the recommendations.
Ms. Throwe asked for the Board's feedback on Mr. Weiss' suggestion.
Mr. Zimmer asked for Mr. Weiss to repeat his point.
Mr. Weiss said the first sentence in the third paragraph has a parenthetical that there should not be offsets to other
programs, recognizing this is with respect to creating a new SRF or adding additional funding to the CWSRF. He
suggested that parenthetical be placed in an introductory paragraph, as it applies not only to the third recommendation
but also to the first and second. The Board wants Congress to appropriate additional funds for stormwater but not to
reduce existing programs.
The Board agreed.
Mr. Zimmer said the CWSRF and DWSRF are two very separate programs. They are from two different laws and
managed by two different groups. He noted the recommendation currently uses terminology that suggests the existence
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of a generic SRF program. He suggested the Board specifically recommend larger appropriations "within the existing
Clean Water SRF/' as that is the SRF where stormwater is housed. He also proposed revising the next sentence to
emphasize the recommendation for financial commitment that is additive. The sentence would then read, "It is the view
of the Task Force that stormwater would benefit from a separate, additive recurring financial commitment from EPA."
The Board agreed.
Mr. Holland asked if the report defines these terms.
Ms. Tarquinio said there is an acronym section just before in the Table of Contents where the terminology will be
included.
Ms. Lemoine said the second part of the first paragraph, starting with "stormwater management is a critical policy
issue," should be a new paragraph.
Mr. Crooks said the second recommendation starts with "educate elected officials." He asked if the Board Members
would want to ask for funding to educate elected officials. If so, they should add that to the recommendation.
The Board agreed.
Ms. Throwe shifted the focus of the Board to the first panel on opportunity zones. She asked the Board Members to
remember the current discussion for when they return to it later in the day.
Mr. Holland noted there are a number of people for whom this EFAB meeting is their last. He asked the Board to
acknowledge their service at some point during the day.
Ms. Throwe agreed and said she would incorporate that into the agenda.
Proposed Charge to EFAB - Opportunity Zones
Mr. Chu noted, after the Backhaul Alaska consultation and Stormwater Task Force report, the ongoing work of the Board
will be done. New Board Members will convene in August 2020. It is a good time to begin considering a set of new
charges for the next phase of work (Attachment M). Mr. Chu noted the first charge will be presented by EPA leads, and
three other proposed charges will be introduced by Board Members. Mr. Chu asked that the Board Members recall the
SOP in how they consider new charges.
Mr. Chu introduced Helena Wooden-Aguilar, the Deputy Associate Administrator in the Office of Policy, and Brittany
Bolen, the Associate Administrator for the Office of Policy. Ms. Bolen is also the Senior Policy Advisor to the
Administrator. The Office of Policy and Ms. Bolen hold important positions within EPA, and they are here to present a
charge on their initiative with Opportunity Zones.
Ms. Bolen wished everyone a good morning and thanked the Board Members for their service. She recognized their
impressive backgrounds and expertise. She acknowledged EPA Administrator Andrew Wheeler sends his regrets for not
being able to meet with the Board Members this week. She said he looks forward to receiving their recommendations
on a number of products they are considering.
The Office of Policy is housed in the Office of the Administrator and works across the Agency and the regional EPA
offices. It is the chief policy-making arm of EPA, tasked with identifying ways to advance the mission of protecting
human health and the environment. The Office is structured to advance that mission through two multi-disciplinary
tracks. One track is through traditional regulatory work (e.g., implementing statutes, policies, and permitting processes).
Within the Office of Policy is the Office of Regulatory Policy Management, the National Center for Environmental
Economics, and the Office of Federal Activities. The second multidisciplinary track is the more innovative side of the
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Office of Policy, dedicated to advancing the mission through collaborative problem-solving and external community
engagement. Within this track is the Office of Environmental Justice and the Office of Community Revitalization. They
also have a Climate Adaptation Team and a sectors-based program interested in engaging with industry and regulated
communities to identify best practices for advancing the EPA mission.
Ms. Bolen moved to discussing opportunity zones. When President Trump signed Executive Order 13853 on opportunity
zones, the Administrator designated the Office of Policy to lead the EPA's implementation and coordination of
opportunity zone work. She said it was a natural fit, particularly because of the Office of Environmental Justice's
longstanding work developing community-driven solutions. Opportunity zones are economically distressed communities
that have been formally created and designated by the governors of each state. Currently, there are more than 8,700
census tracts designated as opportunity zones. They were designed to spur economic development and encourage job
creation in distressed communities by providing tax benefits to investors. In December of 2017, the Tax Cuts and Jobs
Act was signed into law, establishing this tax incentive program to promote equity investment in low-income
communities. A year later, in December 2018, President Trump signed Executive Order 13853, establishing a
Revitalization Council to carry out the White House Administration's plans on how to target, streamline, and coordinate
federal sources and programs to be used in opportunity zones. EPA is one of the agencies on the Revitalization Council.
The Administrator participated in the first meeting of the council with President Trump in April 2019. Ms. Bolen regularly
participates in the staff-level meetings and engagements for the Council.
On the Council, EPA participates in two of the six workstreams: economic development and safe neighborhoods. The
economic development workstream is tasked with leveraging federal grants and loans in a more integrated way to
develop dilapidated properties and to provide basic infrastructure and financial tools to attract private investment. The
safe neighborhoods workstream is tasked with finding ways to make these opportunity zones safer with the reasoning
that a safer community is a more attractive community. Some of the items the workstream has discussed is how to
combat drug addiction and the opioid crisis, reduce crime, enhance public safety, and address environmental
contamination.
The workstreams were designed to pull together different agencies with different levels of expertise to focus on six
areas that would have the most impact in furthering the implementation and incentives for opportunity zone
investment. EPA recently worked with the rest of the Council on a report that went to President Trump in February 2020
about the workstream-specific programs, activities, and accomplishments. The report also identified other actions to
advance this work.
Ms. Bolen shared a few examples from the report within EPA's two workstreams.
1. For the 2019-2020 Environmental Workforce Development and Job Training Grant, EPA has included the
location of brownfield projects in opportunity zones as another factor that could serve as a tiebreaker.
2. EPA has included language in the guidelines for the 2020 Brownfields Assessment, Revolving Loan Fund, and
Cleanup Grants. There will now be additional points given to applications for site-specific locations in
opportunity zones and applications that would directly spur redevelopment in an opportunity zone.
3. The Local Foods and Local Places program within the Office of Community Revitalization is a technical assistance
program in which EPA works to revitalize communities by increasing access to fresh and local food. Over the last
year, EPA has identified opportunity zones as a consideration in selecting the communities with which it
partners.
4. The Environmental Justice Small Grants Program within the Office of Environmental Justice has also added
opportunity zones as a consideration when looking at applicants.
Ms. Bolen said EPA's experience suggests economic investments from the private sector may be more attractive when
environmental quality is maintained at healthy levels, as potential environmental liability leads to uncertainty. EPA
believes additional environmental improvements are necessary, including critical infrastructure projects to attract
private sector investment, and opportunity zones lend to that effort.
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While EPA has been encouraged by the positive feedback it has received on this work, Ms. Bolen recognized this work is
evolving across the country at multiple levels. To maximize the tax exclusion of a qualified opportunity fund, it must be
invested in by the end of 2021. Ms. Bolen noted this approaching year makes the work with the Board all the more
timely.
Ms. Bolen recognized EFAB's expertise and mission to explore ways to lower costs and increase investment in
environmental protection.
She thanked the Board Members for their consideration and introduced the following questions within the draft charge:
1. First, which specific federal/EPA incentives (monetary or otherwise) are most likely to increase public/private
investment in opportunity zones?
2. Looking at existing EPA incentives, including funding programs such as environmental justice or brownfields
grants, which incentives, programs, or approaches are better suited to achieve desired community outcomes
while reducing risk, liability, and/or regulatory uncertainty for investors in opportunity zones?
3. Does the EFAB have recommendations on readily implementable adjustments to existing Agency programs to
make them more effective in reducing risk, liability, and/or regulatory uncertainty? Are there more complicated
adjustments that should be also considered by the Agency?
4. What regulatory/liability/risk data could be provided to allow investors to compare opportunity zones and
determine which opportunity zone might be a best fit for their investment?
5. Does the EFAB have any recommendations on how EPA shares information and resources in a way that would
ensure that the programmatic resources they leverage for opportunity zone purposes lead to improvements in
local health and environmental outcomes for the existing community?
Ms. Bolen said she appreciated any feedback and questions, and she looks forward to continuing to work with the
Board.
Ms. Kim thanked Ms. Bolen for taking the time to explain what the Office of Policy does. She noted these projects are
incredibly complicated and take a lot of time; her main fear is 2021 is not enough time. She wondered if there is any way
or ability to extend the 2021 deadline.
Ms. Bolen noted Ms. Kim is not the first to have voiced such a concern. She said the structure of the opportunity zone
initiative was created through the Tax Cuts and Jobs Act, and the Department of the Treasury drafted the regulations
around its implementation. Though she and EPA do not have control over that part of the initiative, she said she could
raise the point to the broader Council to see what options are available.
Mr. Chu reiterated one of the criteria in the SOP is how EFAB can be impactful under the authority of EPA. Because this
is a federal, government-wide initiative with other agencies involved, he recommended the Board be strategic and savvy
about what they could offer to the Administrator. He noted Mr. Zimmer would be leading this discussion.
Mr. Zimmer said this is an area of interest to many on the Board. He noted the process of investing in an opportunity
zone involves project design, collaboration with a developer, and permitting. He asked if the 2021 deadline is when one
has to expend their funds, or if 2021 is when they must have their contract or loan agreement in place.
Ms. Bolen acknowledged she does not have an extensive financial background. Her understanding is one would need to
have their funds in a qualified opportunity zone fund by the end of 2021. That fund does not necessarily need to have
those resources expended, but it must be in a fund by 2021 to receive the greatest credit.
Mr. Zimmer said the market will figure out how to make the most money in the cheapest and shortest amount of time.
From the perspective of a redeveloper, there are projects that have already been completed. Then there are projects
that will never be touched. Through this tax law, the government is trying to incentivize redevelopers to consider
projects that did not make sense before; it is providing a financial incentive to potentially get over the minimum return
required by investors. Mr. Zimmer said two of the big issues are uncertainty and risk. There is no way to know what is in
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the ground, and even after completing a remedial action work plan, the project may still be too costly to move forward.
He said when Board Members think about this charge, they must consider three things. The first is how they can
minimize uncertainty for the redeveloper. Doing so allows the redeveloper to make the necessary pro forma and cost-
benefit analyses. He proposed the charge should include a component on how to remove uncertainty. Even with the
removal of uncertainty, too much bureaucracy will also impede the program, given the time-value of money. From an
efficiency perspective, the Board will also want to consider the issues they can address to minimize bureaucracy so
people believe this is a worthwhile investment they can pursue on an expected timeline with relatively little hassle.
Lastly, the Board will want to think about the existing programs they could make available to decrease the cost of
financing. If they address those three big concepts, they can come up with ideas and recommendations to make
opportunity zones attractive for redevelopers.
Mr. Anderson said he is one of the redevelopers to which Mr. Zimmer is referring. He has been a redeveloper for over 20
years, and he finds this to be a great charge. He said Mr. Zimmer made a number of good points. There are 430,000+
impaired sites in the United States. Some will never be redeveloped, and others are being worked on every day. Of the
many sites that exist somewhere in between, a small fraction are in opportunity zones. Whatever work is done for
opportunity zones has applicability well beyond that specific program. His question is what the Office of Policy will do
with what the Board develops. He noted a number of the issues relate not to providing money or incentives. The cost of
delay, extension risk, market risk, and cost of capital are far greater in these projects, and those elements are what the
redevelopers use in their decision-making. In this context, these projects are associated with 20% internal rate of return
(IRR) equity deals, rather than the 5% that is customary with banking deals. He expects the recommendations would
involve statutory changes, and he does not know how feasible that is.
Mr. Zimmer asked Mr. Anderson to explain his comment about 20% equity.
Mr. Anderson said the capital stack for one of these deals is such that a developer will bring in an equity partner, as a
bank will not want to be involved. This equity partner will ask for around 20% return on their equity investment. As a
developer, that project is then really expensive compared to a traditionally financed deal with a bank.
Ms. Bolen thanked Mr. Anderson for his explanation. She said EPA welcomes any recommendations but cannot commit
to advancing statutory recommendations. She recognized this is about more than money; it is about programmatic
changes at EPA. She noted EPA has other efforts underway on the streamlining front like geospatial tools that it would
welcome recommendations on as well.
Mr. Chu reminded the Board the charges that Ms. Bolen is asking the Board to consider are very explicit. He noted Board
Members have talked about other recommendations. As they discuss taking on the charge, he urged the Board to decide
on whether to take it as it is or consider how it could be modified. Some of the Board's recommendations could also
encompass asking Ms. Bolen or the Administrator to transmit information about extending the deadline.
Mr. Meister thanked both Ms. Bolen and Ms. Wooden-Aguilar for coming. He observed it is rare for there to be so much
executive support for an initiative at the federal level that impacts the state and/or local level. He recognized the chain
of command that Ms. Bolen and Ms. Wooden-Aguilar represent. He said the national representation and
multidisciplinary expertise of this topic leads him to suggest that several of the points raised by Mr. Anderson and Mr.
Zimmer could take the form of factual observations, given the Board's role in fact finding. With the help of the resources
of the Office of Policy to assist in fact-finding, the Board could make a series of written observations. He recommended
the Board take this charge and fast-track it for consideration at the August meeting. He noted it does not have to be
lengthy, especially with the resources represented by Ms. Bolen and Ms. Wooden-Aguilar.
Ms. Bolen said they would greatly appreciate fast-tracking the charge given its time sensitivity. To Mr. Meister's point on
fact-finding, she said Scott Turner, the Executive Director for the Opportunity and Revitalization Council, has joined HUD
Secretary Ben Carson in visiting opportunity zones around the country to meet with local leaders and gain a sense of
what people on the ground are recommending. She recognized there are limitations to the number of places they have
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been able to visit. While she knows their trip has been beneficial, they do not have something in writing that is as
detailed as what Mr. Meister described.
Ms. Throwe clarified for the Board that they will hear about all the charges first before taking a vote.
Mr. Holland thanked Ms. Bolen and Ms. Wooden-Aguilar for coming and speaking to the Board about the charge. He
agreed opportunity zones address a critical issue and provide a way to increase the capital flowing into communities in
need. Given the critical timing constraints, he is considering what the Board could do. It struck him that EPA will never
be in a position to manage the flows of opportunity zone funds into projects, as it is outside the capacity of the Agency.
He said EPA could do a few other things, though. First, EPA has great convening power. He suggested EPA work quickly
to understand what the existing opportunity zone funds are struggling with in terms of financing and building projects.
Receiving direct feedback from those opportunity zone funds will be critical in determining what steps EPA can take to
ensure whatever money it puts out is impactful. Second, he wondered if there is any precedent for federal agencies
putting out a request for proposals (RFP) for a fund manager who would manage funds that invest into other
opportunity zone funds using specific underwriting criteria adherent to the mission of EPA. He explained EPA has specific
objectives it wants to meet across all the different teams within the Office of Policy. Those objectives could be translated
into underwriting criteria for projects. One potential product of the charge could be an RFP for a fund of funds - that is,
a fund that lends to qualified opportunity zone funds - and the criteria or conditions under which it would lend that
money. If enough people are interested in such an RFP, EPA could at least establish to have funds flowing before the
2021 deadline and determine how to deploy those funds in a reasonable timeframe.
Ms. Kim said, in the past, the Board has convened experts around the table for advice and perspective. She noted it is
not the fund managers with issues, but rather the developers on the ground who are interacting with and applying for
these grants. She suggested, as part of the charge, the Board host a roundtable of developers from different areas to ask
them what programs they are trying to access and why they cannot receive the grant funding and financing they need.
What the Board and EPA really need is to understand the roadblocks for the developers.
Mr. Chu acknowledged Mr. Holland presented potential solutions to the charge and Ms. Kim discussed some of the ways
in which the Board could acquire the necessary information for recommendations. He suggested the Board talk further
about the process of the charge first.
Mr. Zimmer said there are a lot of different ideas and directions the Board could pursue. He asked if the Board could
establish this charge as something they have interest in as a Board and then pick a group to work on how they would set
up the charge for the August EFAB meeting.
Ms. Throwe said Mr. Zimmer's proposal would be allowed, but she would like the Board to go through all the
prospective charges before proceeding.
Ms. Sanzone noted the idea is not to decide whether to accept this charge in August but to decide how the Board would
approach the charge in August, assuming they vote to proceed today.
Mr. Chu noted there is a prioritization of the proposed charges that must take place before the Board votes to proceed.
Ms. Throwe thanked Ms. Bolen and Ms. Wooden-Aguilar for coming.
Ms. Bolen thanked the Board Members for their time, energy, and service. She said they look forward to engaging with
the Board moving forward.
Stormwater Task Force Report - Transmittal Letter
Ms. Throwe transitioned to discussing the Transmittal Letter. She noted the Board Members should have a copy of the
initial draft in their folders. She asked if they would like to list out the recommendations within the Letter.
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Mr. Henifin said they should.
Mr. Zimmer said his style of reading and communicating is to present the key points upfront. He said the Letter currently
addresses the recommendations at the end. He also wondered if the paragraph about stormwater management costs
(paragraph three) is necessary.
The Board agreed.
Mr. Henifin said the Letter should acknowledge the gap in funding right away. After presenting the gap, they could state
the recommendations on how to fill it.
Ms. Throwe said she wants to keep the Letter to a couple of pages.
Mr. Henifin said the Board should make sure to do so.
Mr. Crooks wondered if the Board needed to keep the recommendations in the Letter. He agreed they should note the
substantial gap in funding and the need to fill it, but they could do so without going into great detail about the
recommendations. Rather, they could summarize the recommendations after the introductory paragraph.
Ms. Beecher agreed. She suggested they include a one-page of the recommendations in an Appendix at the end.
Ms. Throwe said her concern with Mr. Crooks' suggestion is if the Transmittal Letter is all that is read.
Ms. Lemoine said the third paragraph of the Letter summarizes the recommendations without too much detail. If the
Board moves that paragraph higher to the opening of the Letter, they could get their point across.
Mr. Anderson said the Board seems to be struggling with who will be reading what parts of the report. He suggested
they may be overthinking and proposed making the Letter two paragraphs. The other information could be included in
the Executive Summary.
Mr. Crooks seconded Mr. Anderson. He said Congress asked for a report, and the Board produced a report. Congress did
not ask for a Letter.
Ms. Tarquinio said she does not think the Transmittal Letter will go in the Appendix of the larger EPA report to Congress.
It will go to the Administrator.
Ms. Throwe noted this Letter will be read and will have her name on it. She asked the Board what their one point would
be to get across.
Mr. Anderson turned the question back to Ms. Throwe and asked what one point she would want to make.
Ms. Throwe said the paragraph on the second page of the report that notes how the Task Force analyzed the funding
needs of communities and emphasizes the need to prioritize stormwater captures the meaning for her.
Mr. Zimmer agreed. He said he does not think this is a two-page Letter. He said the Board should build out the
paragraph Ms. Throwe identified and state their recommendations. He thinks they should distill in two paragraphs the
work that everyone did, as if they were pitching their findings to the Administrator.
Ms. Throwe said she is comfortable with that approach and wants to come out of the gate with the Letter. She said she
has recorded the Board's feedback for when she revises it. She asked Ms. Sanzone if the Board could take a vote on the
report at this time, including the Executive Summary. She recognized they could not take a vote on the Transmittal
Letter until everyone has had the opportunity to review the final version.
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Ms. Sanzone said Ms. Throwe could ask for a motion regarding the finalization of the report, including the Transmittal
Letter, subject to the discussions to which the Board has agreed.
Ms. Throwe asked if she had a motion for the report.
Mr. Crooks moved that the Board finalize the documents of the report, including the Executive Summary and
Transmittal Letter, in accordance with their discussion over the last three days and authorize Ms. Throwe to transmit
their work to the Administrator.
Ms. Throwe asked for a second.
Mr. Anderson seconded.
Ms. Throwe asked for a vote on the motion.
Fifteen members being present and constituting a quorum, the motion passed unanimously.
Proposed Charge to EFAB - Risk and the Cost of Capital
Ms. Beecher proposed a new charge on risk and the cost of capital for utilities, a topic around which many of the Board
Members have coalesced. Specifically, the charge seeks to address the intersections of environmental and financial risk.
She noted how Standard & Poor's Financial Services, Moody's Investor Service, and others are starting to look at risk,
reliability, regulatory compliance, and resilience. There is an opportunity to consider how players in the market,
including credit agencies, are dealing with risk-related issues.
Ms. Beecher shared the following key questions listed in the proposed draft charge:
What risk factors (including environmental risks) are affecting utilities and how are they being addressed?
Examples of risk impacts include cost (increased capital or operations scope, reporting and administrative
effort, etc.), schedule (delays due to required environmental permits/approvals), and increased uncertainty
about project viability (affecting cost of capital and increasing contingencies).
How can utilities more effectively manage risk, and which tools are most cost-effective for which risks?
Which categories of risk have been the most challenging for utilities to manage effectively, and why?
How are utility credit ratings and insurance products affected by risk?
How is changing risk affecting utility capital costs and revenue requirements?
How does utility ownership affect risk management?
For the private sector, how are risks shifted between shareholders and ratepayers?
How does risk-bearing relate to issues of environmental justice?
What practices and products can utilities use to manage or mitigate risk?
How are various types of risks disclosed and reported?
What tools are available for evaluating risk, including scorecards?
Ms. Beecher considers risk and the cost of capital to be a natural topic for the Board and EPA to consider. The Board
would need to consider who within EPA might be interested in this work. Ms. Beecher noted a forum may be useful to
apply to this charge. Another possible product could be a webinar or seminar to help those who do not have the
financial background to understand these terms or issues.
Ms. Throwe returned to Mr. Chu's earlier point about what the Board can offer EPA.
Mr. Crooks said he was a minor contributor to the first draft of this proposed charge. In reading and thinking about the
issue, he was struck by its breadth and depth. He said the Board should consider focusing on a particular aspect of risk.
He suggested focusing on climate change and how those risks are affecting the cost of capital. The Board could also
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focus on environmental regulatory risk. He acknowledged there is also a lot of existing written material on risk, and the
Board would not want to replicate what has been done elsewhere. The Board will need feedback from EPA staff as to
what would be useful in accomplishing their objectives.
Mr. Weiss agreed the Board needs to narrow the scope of the charge. He is seeing an increasing focus by investors on
bond and equity markets. This topic has a direct implication on the cost of capital and the ability of EPA to achieve its
mission to improve the environmental situation for utilities. He said part of the charge may relate to education and part
of it may relate to things EPA could do with its policies to help utilities address risk mitigation.
Mr. Stannard said, when thinking as an advisor to municipal utilities, Ms. Throwe's comment is very important. The
Board needs to frame this topic in a way that is a nexus with actionable items for EPA. He asked how they can help utility
management understand and expand their approaches to risk mitigation and relate that to what EPA does. He agreed
the Board needs to narrow the charge and focus on an actionable outcome.
Mr. Henifin said, as a utility and member of the regulated community, his utility is often accused, and rightfully so, that it
is risk averse. He explained there is an imbalance in the public sector between risk and reward. There is no upside to
taking risk in the public sector. Public sector entities are slow to adopt new technology because there is little reward for
being the first one out if it does not work. He said there is an action here for EPA to figure out how to build a permit and
regulatory environment that would support risk taking. Doing so could save a fortune in capital investment.
Ms. Kim said in any equity or debt document, there is a huge section on risks and how to mitigate them. She said the
Board's work could be a tool for EPA. The Board could write an outline of this section for smaller entities who do not
have the expertise to organize themselves and write about risk as extensively.
Mr. Meister agreed the charge should be narrowed. He noted the needed expertise is already in this room. There would
be a lot of research necessary, and the Board could write about the issue in succinct, plain language. He also finds the
topic timely because of the January release of the McKinsey report and Larry Fink's BlackRock letter that recognized a
fundamental reshaping of finance. He said the Board could take on a narrower version of this charge quickly and return
to the next EFAB meeting in August with something useful to EPA.
Mr. Zimmer said he likes the idea of narrowing the charge down to focus specifically on climate change. As a lender to
utilities, he considers it to be relevant and cutting-edge. He seconded Ms. Kim's comment and added that rating
agencies are looking at climate change. He noted the risk-reward issue is not about what one will be paid but what one
will be penalized. He supports this charge because it presents an opportunity to help EPA get in front of this issue with
regulatory guidelines for his clients.
Farewell to Departing Board Members
Mr. Chu explained the process of how the next iteration of the Board will be assembled.
The terms for all the current Board Members expire at the same time except for Ms. Throwe. There was a Federal
Register notice seeking nominations for the Board, and the Administrator will select the members. The Federal Register
nomination period has closed, and there is now an internal process taking place. There are several Board Members who
have six years and are no longer eligible for re-nomination. The majority of the Board has not termed out. By June 2020,
before the expiration of the current terms, there will be a decision about the composition of the next Board. He cannot
say what will happen, but from previous processes, there is a high likelihood that many will be sitting on the Board
again. There will not be a gap in the terms for those re-nominated and reappointed.
Mr. Chu had intended to have a ceremony for the current Board Members. This is a particularly important Board as the
Board Members are the class of 2020 during the 50th year of the EPA. He noted they will all be receiving something from
him. He is also trying to implement a procedure for welcoming new Board Members and saying farewell to old Board
Members. He acknowledged the feedback he received about how strange it is in first joining the Board. If Board
Members are reappointed, they may be asked to assist in the onboarding process of new members.
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Mr. Chu said the Board Members have been a spectacular group for him, personally. He thanked the Board Members for
their feedback, and he hopes they know the impact they have made not only on EPA but also on how EFAB functions
and will continue to function moving forward.
Ms. Throwe recognized there are a few Board Members who have reached the end of their terms. She acknowledged
Ms. Daniel, Ms. Kim, and Mr. Crooks. She said they are all family, and though she has been around for some time, it is
difficult to say goodbye. She expressed her sincere appreciation for their six years of hard work and extensive expertise.
She asked if they had any favorite projects or parting words.
Mr. Crooks said one of his favorite projects was on transit-oriented development, a project on which all three of them
worked. He reflected on how much the Board has improved its operations and approach. He said the process was very
ponderous then, and he finds the Board now is more efficient, effective, and impactful. Its ability to deliver has
improved dramatically, for which he thanked Ms. Throwe, Mr. Chu, and the Board.
Ms. Daniel said participating on the Board may be one of the most rewarding things she has done in her career. She said
it has been a pleasure to sit around a table with such brilliant minds. She explained she is engaged the entire time
because of the thoughts and creativity on the Board. She agreed the Board has improved its process dramatically in
capturing the value of its members.
Ms. Kim said she has really appreciated this opportunity. She said, of the last six years, this current Board comprises the
most engaged group of people, and she recognized the Board Members' devotion to the mission of improving their
environment. She said one highlight for her was having the White House adopt some of their recommendations. She
was subsequently invited to a roundtable to discuss tax policy.
Ms. Daniel said it is also invigorating that the Board's discussions carry on beyond the table. She remembered one
meeting in Washington D.C. when there was a fire drill, and she and her fellow Board Members came up with the green
bond initiative while standing outside the building.
Mr. Chu noted these three individuals are not the only ones who will say farewell. Others will be voluntarily stepping
down from the Board. The current process does not allow him to say more about potential retirements and
reappointments, but he said the Board will be revising this process to allow for more open acknowledgement of
outgoing member contributions moving forward.
Ms. Throwe thanked those who will be leaving and said they will be missed.
Backhaul Alaska Debrief
Ms. Throwe asked the Board to revisit its consultation for Backhaul Alaska. She asked if the Board effectively closed out
the request from EPA and if the Board had additional comments.
Mr. Meister said, upon reflecting on the comments made yesterday, he believes the consensus was this was a failure of
key stakeholders and local and state government. He noted Backhaul Alaska is the sort of collective market and public
policy governance failure that is becoming increasingly common across the country. He moved for two things. First, he
moved the Board to notify the Administrator in a letter of consultation about this failure and recommend EPA find a sum
of money to immediately address the situation. Second, he suggested the Board Members use the business plan they
collectively outlined yesterday to work with the sovereign state, local government, and tribal entities to develop a
sustainable solution.
Ms. Daniel agreed.
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Mr. Zimmer said there would, in the very least, need to be a constraint on the recommendation for support like a dollar
amount or time limit. He reiterated Mr. Henifin's comment that Alaska is a wealthy state. As a representative from
another state, he said he did not know if he would be willing to include such an addition to the letter of consultation. He
said he has an issue with asking the federal government to give Alaska money to bail them out.
Mr. Henifin said he is of the same opinion as yesterday. He does not see where this request would solve anything for a
sustainable future. He does not believe it is the role of the federal government.
Ms. Daniel noted Ms. Carvalho and the Solid Waste Alaska Task Force have been working on this issue for two and a half
years. While the Board engaged in helpful work yesterday, she noted the Board Members all left with some feeling of
dissatisfaction about the situation. She said she does not see a one-time bailing out as a sustainable solution.
Ms. Lemoine said she agrees with adding a statement about the failure of state government and the need for something
to be done. Her concern with asking EPA for funding is that there are unique problems throughout all 50 states and
territories. She would like to see a more sustainable approach if the federal government is going to get involved.
Mr. Rothstein agreed with Ms. Lemoine, Mr. Henifin, and Mr. Zimmer. He finds bailing out a local government for its
failures to have little appeal. He noted, at the same time, they saw in Flint that the local and state government failed,
and EPA was condemned for not addressing the issue in a faster, meaningful way. Backhaul Alaska is an example of
consistent local and state government failures occurring throughout the country and posing significant environmental
justice issues. Rather than ask for money for this particular problem, he said it should be recognized as one of several
problems. He suggested there may be a charge to look into a funding mechanism that deals with how to address state
and local government failures that lead to a significant environmental justice issue. The Board could use Backhaul Alaska
as a pilot or example. He noted the Board must be very careful and thoughtful about the criteria by which funding is
provided. EPA should function as a backstop in providing service to low-income and economically disadvantaged
communities, not a parachute for failing local and state governments.
Mr. Kaplan said he strongly supports Mr. Meister's recommendation. He said the provision of federal funding or support
would not be intended as a permanent measure. By citing the progress made by the Solid Waste Alaska Task Force, the
Board is highlighting the existence of an organization dedicated to remedying the situation. EPA would be stepping in
because there is an immediate problem that needs to be addressed by the local people.
Mr. Zimmer said he is in the same place as Mr. Kaplan. He noted he differs from Mr. Henifin in that he is more
comfortable asking for money because there is a plan in place that needs seed money. The state would then be stepping
in to make sure the program continues. The Board is really asking EPA to be the incubator.
Mr. Anderson said he is torn. He likes the idea of acknowledging the failure of the state to comply. He is opposed to
potentially setting a precedent, and he noted there may even be constitutional issues with funding a program in this
way. He would support the seed money if it was directly tied to implementing something. He acknowledged the Board
would not even be in this position if not for Ms. Carvalho and her team. Their tenacity and initiative with this program
sets Backhaul Alaska apart from throwing money out as a last resort.
Mr. Stannard noted the Board has spent a significant amount of effort on this issue. Yesterday, the Board Members
developed frameworks that could be the basis for implementing a governing structure. He wondered if they could ask
for the provision of funding not to assist with everything, but to help the Backhaul Alaska program reach the next step
so, at some point, all the stakeholders are engaged.
Mr. Chu urged the Board Members to do more factfinding on the other issues they are raising about EPA funding. Since
the 2018 Appropriations Act, EPA has allowed money from IGAP to be used for paying for the Backhaul Alaska program.
He would urge the Board to learn more about that change from Congress before making any recommendations about
allocating money. He said the question may be more about targeting and addressing issues related to that funding.
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Ms. Beecher said she is comfortable with providing some kind of recommendation to the Administrator. To Mr.
Rothstein's comment, she would step back and think about Backhaul Alaska as a financing problem. She noted the need
to be more proactive about reestablishing a culture of compliance. Backhaul Alaska should signal a broader problem.
Ms. Kim asked if the Board could condition the seed money with matching state or local funds.
Ms. Throwe noted this letter will have her name on it, and she needs to be comfortable knowing the Board is supporting
its direction. She said she is interested to see something go in the letter beyond the original acknowledgement of the
consultation. She would like more time to consider what that looks like and asked Ms. Sanzone if that would be allowed.
She would also like a small group to work with her in talking through these possibilities. She reiterated how impactful
the Board could be here.
Ms. Sanzone said whatever the letter becomes, the Board would need to see the final draft by email to approve it.
Ms. Throwe asked for a small group to work with her on the letter before bringing it to the full Board.
Mr. Meister articulated Ms. Throwe's request as a motion. He moved to delegate to Ms. Throwe the authority to
convene a small group of Board Members within the parameters of FACA to advance an additional recommendation to
the Administrator in light of market and governance failure.
Mr. Holland seconded Mr. Meister's motion.
The Board all voted in favor.
Members Anderson, Beecher, Crooks, Daniel, Henifin, Holland, Kaplan, Kim, Meister, Rothstein, Stannard, Weiss, and
Zimmer volunteered to help Ms. Throwe.
The Board took a break and reconvened at 11:28am.
Proposed Charge to EFAB - Stormwater Credit Trading
Mr. Holland said increasingly in the National Pollutant Discharge Elimination System (NPDES) permit writing process and
because of dwindling flows into stormwater utilities, cities and municipalities are looking for ways to offload some of the
responsibility for stormwater management onto the private sector. Specifically, they are looking at those developing
new impervious areas in cities. Within the permit writing process, there is usually some compact between the
municipality and the regulator to put in place a post-construction stormwater ordinance which obligates developers of
new properties to stormwater management. The specifics of what is in the ordinance is then left to the political process
of the area. Within that framework, there is an opportunity to create markets around those ordinances. These markets
are effectively compliance offsets from where the property is being developed to where the stormwater management
takes place. Washington D.C. was the first place in the country to have such a trading market and has been successful in
driving both environmental and social outcomes. The market has also brought more financing into the stormwater
space, completing larger projects at cost-efficiencies while also maintaining the compliance obligations that exist under
its municipal separate storm sewer systems (MS4) permit and Total Maximum Daily Load (TMDL) obligations within the
Chesapeake Bay.
Mr. Holland said The Nature Conservancy participates and invests in this market. The organization has helped think
through various ways in which these markets can be run more efficiently, and its reports can be accessed online. Other
communities have since been asking consultancies and non-governmental organizations how to implement their own
stormwater credit trading programs. Given the interest across the United States, he sees an opportunity for EFAB to put
together guidance for permit writers on how to create the ability for communities to institute stormwater credit trading
within the permit writing process. This work could comprise one or more of the following:
Environmental Financial Advisory Board Meeting, February 11-13, 2020
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1. The ways in which to institute a stormwater credit training market within the permit writing framework and to
obligate communities to do so within the five-year permit writing cycle
2. A study into what needs to happen for a credit trading lane to take place
3. Guidance on the various considerations that a municipality would need to take to successfully implement a
program like this
Mr. Meister said he finds the proposed charge to be well thought out. He thinks there will be more discussion, but he
would like to move forward with this charge. It is relevant, flows out of the recommendations to Congress the Board is
working on, and, locally, Illinois could use these kinds of resources.
Mr. Weiss said he is familiar with other types of trading programs, and he asked if this approach could be done on a
watershed-basis or only a community basis.
Mr. Holland said ideally, with any market, there is as much volume as possible and at scale supply and demand. That is,
ideally, this would exist at a watershed scale. There are challenges, though. Within the Chesapeake Bay TMDL
framework, there is authorization from the Chesapeake Bay program to look at a nutrient trading market as a means of
compliance. However, each state within the Chesapeake Bay watershed has its own trading framework and language. He
thinks the Board could recommend that ideally if one of these markets is going to be put in place, it be on a watershed
basis. However, doing so will require reconciling peculiarities of regulation sitting at various units of government. This is
not impossible to overcome, but it is a challenge.
Mr. Crooks sought to better understand the nature of the advice the Board would give. Would the charge center around
the commercial, legal, and financial structuring of these trading programs? Would it deal with the technical aspects of
what stormwater and treatment assets could be included? Is there a narrowing of focus that might be useful?
Mr. Holland said he would not recommend the Board try to develop guidance around the specific best management
practices that would make one eligible for credit certification. In his experience, that is a very locally determined
decision and appropriately so, as each watershed is dealing with different issues. With this charge, he suggested the
Board focus on the policy and regulatory measures that would need to be in place to have a functioning market and the
administrative concerns that the permittee would need to implement to administer and manage that market.
Mr. Crooks said presumably the permittee would then address all the situation-specific issues.
Mr. Holland said that is correct. Typically, when a city institutes a post-construction stormwater ordinance, it will create
guidance on eligible best management practices (e.g., local permitting) for implementing the program.
Mr. Stannard said he appreciates this concept, as it is an issue many cities are dealing with outside of a market. He asked
if he was correct in understanding there would be guidance to the permit writer as well as the permit receiver.
Mr. Holland confirmed Mr. Stannard is correct. The Board would want to have guidance on both ends, so everyone is
operating from the same set of facts and language.
Mr. Stannard said there would be opportunity to take this concept further as well to things like green infrastructure
where multiple communities are involved.
Mr. Holland said one of the issues in this space is when people try to measure the common denominator across different
ordinances, as they are all measured differently (e.g., cost per square foot, cost per gallon managed, impervious acre
treated credit). To get these programs operational across the country, there needs to be some sort of standard for what
a credit means. Then the private market would be more interested in engaging. Right now, the translation costs to enter
into these markets is very high.
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Ms. Throwe noted a few members have to leave early. She asked if the Board could postpone their discussion on the
proposed charge on water affordability to the August 2020 EFAB meeting.
Mr. Henifin said that would be fine.
Voting on Proposed Charges
Ms. Throwe said the only official charge before the Board is on opportunity zones. She said the Board would need to
discuss whether to move forward with that charge before determining whether there is capacity to develop official
charges for the other proposed topics.
Mr. Zimmer made a motion that the Board Members consider moving forward with the charge for opportunity zones
with the idea that they would be able to modify it at some point.
Mr. Meister seconded Mr. Zimmer with the addition that the Board delegate to Ms. Throwe the ability to narrow the
charge with Board consensus with a revised charge to be take up at the August 2020 EFAB. .
Ms. Throwe moved to a vote to take up the charge as amended.
The Board voted in favor.
Ms. Throwe moved to the proposed charge on risk and the cost of capital.
Mr. Crooks proposed that Mr. Chu and the EPA support team take the concept of this charge back to EPA, shop it
around, and find what would resonate most. He said he agreed with Mr. Zimmer's point on the cutting-edge nature of
climate change risk, but he acknowledged it may not be what EPA wants to prioritize.
Mr. Holland agreed but cautioned the Board about taking on a charge too broad in scope. Unless the charge is narrowed
down to a few key points, it will be difficult to complete.
Mr. Chu said it would be difficult for him to find a client at EPA at this time because the charge is so broad. He asked the
Board Members who proposed this charge to narrow the scope and identify potential client offices.
Mr. Weiss said he agreed the group should narrow the focus of the charge to bring to Mr. Chu.
Ms. Throwe asked the Board to vote on having the subset of Board Members modify the charge for their review prior to
sending it to Mr. Chu.
The Board all voted in favor.
Mr. Chu noted, for Mr. Crooks, Ms. Daniel, and Ms. Kim, the expiration of their terms on the Board is April 5, 2020. He
recognized Mr. Crooks is a part of the group that proposed this charge, so that establishes a deadline for narrowing the
focus. The other Board Members have until June 15, 2020 in case they are not re-appointed.
Ms. Throwe moved to discuss the proposed charge on stormwater credit trading.
Mr. Anderson said all three proposed charges have merit but seem to need refinement and client selection. By
comparison, the opportunity zone charge is ready now.
Mr. Chu said, if the Board thinks the charges warrant going to the next step, it could propose the Board Members
further refine their respective charges and identify a specific client office.
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Ms. Throwe said she also needs to hear if the Board has no interest at all in the proposed charge topics.
Mr. Holland proposed the Office of Water as the client office for his specific charge.
Mr. Anderson moved that the proposed charges on stormwater credit training, affordability challenges, and risk and cost
of capital be further refined and that the Board Members identify offices that may sponsor their respective charges
before the August 2020 EFAB meeting.
Mr. Holland seconded.
The Board voted in favor.
Public Comment on Proposed Charges
Ms. Throwe opened the time for public comment at 12:00pm. No one was registered in advance, but Ms. Throwe asked
if anyone attending from the public would like to comment.
Ms. Sheils introduced herself from the New England EFC in EPA Region 1. She is the incoming president for the EFC
Network. She agreed that the opportunity zone charge and the other proposed future charges are incredibly relevant,
and the EFCs have current work on projects related to them. For example, the New England EFC has a NOAA-sponsored
project with Maine Water related to the proposed charge on risk and the cost of capital. Using a state-of-the-art model,
EFC staff are trying to figure out what categories of risk have been the most challenging for utilities. They are learning it
is the timing of when utilities should invest in adaptation measures. She emphasized the EFCs are working directly with
communities on projects they can bring to the Board. In the past, the EFCs have been included on charges as expert
witnesses. The experiences the EFCs have with their communities are a direct tie to what is going on at the local level,
and she said the Board could greatly benefit from their input in the future. She thanked the Board for their time and
appreciated their consideration of the EFCs as a source for consultants and subject experts.
Ms. Throwe confirmed no one else wanted to provide public comment.
EFAB Organization and Effectiveness
Ms. Throwe asked for feedback from the Board about how they organize themselves and how they could amplify the
impact of their products.
Mr. Zimmer said he sees this as a push and pull. He said the Board can be more proactive once their products are made
more available for the public. The Board could start initiatives to ensure there is a broader distribution. Conversely,
there could be a pull when their products go to EPA. He noted there is a feeling that their products go to the
Administrator's office, are posted online, and that is it. The perception is there is no additional work by EPA to actively
distribute or act upon their findings.
Mr. Chu said the process of distribution is wrapped up in the charge. He said this discussion ties back to what the work is
and its impact. He noted the report to Congress will have greater amplification regardless because of the potential
impact of some of their recommendations. On the proposed charge on stormwater credit trading, the question is who
the audience will be. He agreed with Mr. Zimmer that there will be a narrower set of audiences. He would urge the
Board to consider audience and impact when accepting the charges. The tenures of the Board Members are limited, and
they just accepted one charge and three prospective charges. He asked which of those three they would consider, using
criteria like potential audience and amplification.
Mr. Zimmer asked if he is suggesting the Board consider a ranking methodology that includes the potential impact of
each charge.
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Mr. Chu said he is not necessarily suggesting a ranking methodology. He said in the past the Board has tended towards
creating reports, and some of those reports have had a very narrow set of audience members (e.g., the recent EFAB
report on the Chesapeake Bay). The question is what the Board would prefer between that approach and something like
the report to Congress. He stressed he is not offering commentary about either report. Instead, he wants to emphasize
how the Board could tackle amplification within the process of accepting charges.
Mr. Anderson emphasized Mr. Chu's point that there have been enormous changes in the Board. He said the Board has
transitioned from charges about strictly finding money to charges about changing the way EPA thinks. He said it is really
important to continue thinking about how to leverage private investment, and he finds the Board's real value is its
intellectual capital. He asked how to employ that in an actionable way. He said the exercise the Board Members did
yesterday for Backhaul Alaska was a big step forward, and they should continue considering different approaches to
their work. Additionally, for those on the Board in August, they have a responsibility to work with new Board Members,
embracing what they bring while carrying forward the culture and investments of this current Board. He said this
meeting has been the most productive he has attended thus far.
Mr. Meister suggested Ms. Throwe and Mr. Chu follow up with Ms. Bolen about these three prospective charges. He
said Ms. Bolen recognized the elements of EFAB and tied them to her mission for innovation. He said the other
opportunity, given how Ms. Throwe and Mr. Chu have and will continue to establish themselves as multidisciplinary
resources of intellectual capital, would be to begin working with the Office of the Administrator to allow member terms
beyond six years on a case-by-case basis.
Mr. Henifin said the idea of writing more reports is not thrilling. He said a lot of report writing is a grind, rather than
generating ideas and working off the Board Members' intellectual capital. He finds the Board would do a lot more if the
Board Members could spend time generating creative ideas. The piece that frustrates him about amplifying the reports
is he has no idea as to whether those recommendations will be taken up. He would like to see further follow-up in that
regard, otherwise there is no purpose to amplifying something that never happened.
Ms. Kim said the Board used to make recommendations based more closely on their audience. For a charge related to a
rule promulgation issue, for example, the Board invited the White House and had representatives attend the meeting. If
EPA cannot deal with funding things, then the Board's audience should be the people responsible for putting together
budgets. Those individuals should be attending the meetings. The Board needs to invite the people who can either
directly implement the change or push back on the feasibility of their recommendations.
Ms. Throwe said the Board is and should be multi-media. The Backhaul Alaska consultation was indicative of the
different types of work they should do. She noted the Board has also been very focused on water over the last few
years. She wondered if EFAB should sit in the Office of Water or if they need to be recognized higher.
Ms. Kim noted she once tried to propose a charge in the Office of Air and was not met with a positive reception.
Mr. Chu said the Board is providing advice to the Administrator, and Ms. Throwe's comment really addresses the impact
and relevance of their work. While he cannot speak to what Ms. Kim experienced, he noted there were two people from
the Office of Air sitting in the audience during the meeting today. He said if a lot of the work the Board does is focusing
on one media, as it has the last few years, then that is how the Board will be known. It depends on what impact the
Board wants to make. His thought is the Board should keep in mind moving forward the kinds of work they take on and
the level of advice they provide.
Ms. Kim thanked Mr. Chu and Ms. Throwe for all the people they have worked to bring to the Board meetings.
Ms. Throwe said expanding the focus area is something the Board could work on. The Board has traditionally used the
EFCs as a major resource to help backstop the Board and provide a local perspective. The Board should continue to
leverage this relationship with the EFCs moving forward. Ms. Throwe noted, due to limited resources, representatives
have been invited to highlight at least a couple of the EFCs each meeting.
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Mr. Holland said this is a great and necessary conversation, one that was lacking when he first joined the Board. He has
seen the Board, over the last four years, be more discerning about how they think about charges and interacting with
clients. On the point of amplification, he noted the Board is limited but their clients are not. The clients are the ones who
will take the recommendations and move them more into the public sphere or within EPA, as evidenced by the Backhaul
Alaska program. He said EFAB was very passive in the beginning about the charges that were accepted. He encouraged
the Board Members to not only spend a lot of intellectual capital on refining their respective charges but also on refining
their clients or audiences. Consideration around amplification will be a part of that process.
Mr. Crooks agreed with Mr. Holland. He said the process of being more discerning about taking on charges must be
informed by some understanding of how the Board's recommendations have or have not been impactful over time. He
said if the Board can better process the outcomes of their work, then they can better navigate trends and understand
where they have impact and where they do not.
Mr. Chu said, when drafting the SOP, the Board discussed the role of receiving responses from EPA clients. When Board
Members make recommendations, they can ask for a specific reaction or update as to what has happened after a period
of time. He recognized how the Board would want to know whether their recommendations are useful to EPA.
Ms. Sanzone confirmed the SOP states that, after the Board submits their report, they will request a post-response
briefing to understand what has come from their recommendations.
Ms. Throwe noted, as the Chair of the Board, she will ensure the conversation does not end here. At every meeting the
Board can continue to refine the way they manage charges and the follow-up to their work.
Mr. Kaplan noted there was mention yesterday that the Board's reports go to AWWA, National Association of Clean
Water Agencies, and other industry organizations. He asked if industry organizations have participated in or been
solicited by the Board to provide comments and feedback in the past.
Ms. Throwe said such industry experts have been on the Board in the past. At various times, the Board has had expert
consultants come in.
Mr. Anderson asked if there are criteria as the Board develops and chooses charges.
Ms. Sanzone said the Board does not have formal criteria for how to decide which charges to select. The Board needs to
continue to build the expectation about the nature of the responses expected from EPA clients.
Mr. Chu noted Board Members built the clause into the SOP for that reason. They wanted to create a kind of muscle
memory about how EPA and EFAB interact with one another.
Ms. Throwe asked if the Board felt she was going in the right direction by considering relocating EFAB from the Office of
Water, perhaps into the Office of the Administrator. Doing so may elevate the conversations of the Board.
Mr. Stannard said he likes the concept, as EFAB was formed to assist EPA with the depth and breadth of its
responsibilities. Being in the Office of Water, the Board will naturally have more of a focus and linkage to water issues.
Mr. Meister also supported Ms. Throwe's idea. He said the Board has an opportunity with the Administrator's Office of
Policy if they deliver on the opportunity zone charge in an effective and timely manner.
Mr. Crooks asked if moving to another office impacts the support EFAB receives from people like Mr. Chu and the EPA
support team.
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Mr. Chu said it would not. He also recognized this topic warrants another discussion. As he understands it, before
coming onto the Board, EFAB resided in the Office of the Chief Financial Officer for over two decades. For reasons
unknown to him, there was an internal EPA reorganization that resulted in EFAB being placed in the Water Infrastructure
and Resiliency Finance Center (WIRFC) in the Office of Water. He noted the question is how such placement is
influencing the work of the Board and its impacts on EPA more broadly. As this is an internal EPA matter, Ms. Throwe is
more so asking if the Board would want to weigh in on it.
Mr. Weiss said it is most important that the Board be as useful to EPA as possible and maintain the support they need.
Ms. Kim noted she may be incorrect in saying so, but she remembers a time when EFAB lost almost all its funding. The
Board had to hold meetings over the phone.
Ms. Throwe said there was less money at one point.
Ms. Kim said her understanding was Andrew Sawyers, current Director of the Office of Wastewater Management at EPA,
was also on the Board at some point.
Mr. Chu said EFAB, like any advisory committee, has always had funding. If EFAB did not have money, the Board would
not have existed. He said his question is if EFAB's placement is affecting their work and its impact on EPA. He noted this
discussion is somewhat precipitative, as it affects even the drive for membership.
Ms. Throwe said the Board seems to be elevating their work. She found it was the right time to introduce such a
discussion because she wants the Board's work to have the recognition it deserves. She thanked everyone for their
efforts over the last few days. She said there is not yet a date for the next meeting, but it will be held in August 2020.
Mr. Chu said farewell to those leaving the Board and is hopeful many can be reappointed. Regardless, he said it has been
a spectacular meeting, and he thanked them for their participation.
The Board adjourned at 12:26pm.
Environmental Financial Advisory Board Meeting, February 11-13, 2020
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Attachments
Attachment A. EFAB Roster, February 2020
Attachment B. Federal Register Notice Announcing the Meeting (85 FR 3678, January 22, 2020)
Attachment C. Meeting Agenda, EFAB February 11-13, 2020
Attachment D. Evaluating Stormwater Infrastructure Funding and Financing Task Force: Task Force Report for EFAB
Review
Attachment E. Evaluating Stormwater Infrastructure Funding and Financing Task Force: Draft Transmittal Letter for
EFAB Review
Attachment F. EFAB Member Pre-Meeting Comments on the Stormwater Infrastructure Funding Task Force Report
Attachment G. Evaluating Stormwater Infrastructure Funding and Financing Task Force: Database for EFAB Review
Attachment H. Public Comment: National Ground Water Association Comments to EFAB
Attachment I. Public Comment: Alternative Compliance and Stormwater Innovation Coalition—Comments to Members
of the U.S. House of Representatives (2/7/2020)
Attachment J. EPA Presentation: Consultation on Financing and Governance Options for Backhaul of Hazardous Waste
from Remote Alaska Communities (2/12/2020)
Attachment K. EPA Webinar Briefing Materials on Backhaul Alaska Program (1/30/2020)
Attachment L. EPA Backhaul Alaska Consultation Plan
Attachment M. Draft Proposed Charges for EFAB Discussion
Environmental Financial Advisory Board Meeting, February 11-13, 2020
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U.S. ENVIRONMENTAL PROTECTION AGENCY
ENVIRONMENTAL FINANCIAL ADVISORY BOARD
Joanne Throwe, Chair
Ed Chu, Designated Federal Official
MEMBERS (February 2020)
NAME
AFFILIATION
REPRESENTED GROUP
Joanne Throwe,
EFAB Chairperson
President, Throwe Environmental LLC, Bristol, Rl
State/Local Government
Brent Anderson
Chief Executive Officer, RESIGHT, Littleton, CO
Business - Industry
Lori Beary
Community Development Director, Iowa Finance
Authority, Des Moines, IA
State/Local Government
Janice Beecher
Director, Institute of Public Utilities, Michigan State
University, East Lansing, Ml
Academic Expert
(Special Gov't Employee)
Theodore Chapman
Senior Director, U.S. Public Finance Department, S&P
Global Ratings, Dallas, TX
Business - Financial
Services
Rudolph Chow
Director, Department of Public Works, City of
Baltimore, Baltimore, MD
State/Local Government
Edwin Crooks
Founder and Principal, Greystone Infrastructure
Advisors, Great Falls, VA
Business - Industry
Lisa Daniel
Managing Director, Public Financial Management,
Memphis, TN
Business - Financial
Services
Marie Roberts De La
Parra
Chief Executive Officer, BMB Construction Properties,
Alameda, CA
Business - Industry
Yvette Downs
Chief Financial Officer, Sewerage & Water Board of
New Orleans, New Orleans, LA
State/Local Government
Ted Henifin
General Manager, Hampton Roads Sanitation District,
Virginia Beach, VA
State/Local Government
-------
Craig Holland Senior Director, The Nature Conservancy, New York, Environmental/Non-
NY governmental
Organization
Daniel Kaplan Financial Services Administrator, King County State/Local Government
Department of Natural Resources and Parks, Seattle,
WA
Suzanne Kim Founder/Managing Partner, Motivate Capital, Tiburon, Business - Industry
CA
Pamela Lemoine Principal Consultant, Black & Veatch Management Business - Industry
Consulting, LLC, Chesterfield, MO
James McGoff Chief Operating Officer & Director of Environmental State/Local Government
Programs, Indiana Finance Authority, Indianapolis, IN
Chris Meister Executive Director, Illinois Finance Authority, Chicago, State/Local Government
IL
James (Tony) Parrott Executive Director, Metropolitan Sewer District of State/Local Government
Louisville, Louisville, KY
Eric Rothstein Principal, Galardi Rothstein Group, Chicago, IL Business - Financial
Services
Bill Stannard Chairman of the Board, RAFTELIS, Kansas City, MO Business - Financial
Services
Carl Thompson Vice President, Sales and Marketing, Infiltrator Water Business - Industry
Technologies, Old Saybrook, CT
Angie Sanchez Vice President/Principal, FCS Group, Redmond, WA Business - Financial
Virnoche Services
Richard Weiss Executive Director, Morgan Stanley, New York, NY Business - Financial
Services
David Zimmer Executive Director, New Jersey Infrastructure Bank, State/Local Government
Lawrenceville, NJ
-------
gpo,
3678
Federal Register/Vol. 85, No. 14/Wednesday, January 22, 2020/Notices
Street, Suite 700, Houston, Texas
77002-2700, by telephone at (832) 320-
5209, or by email at sorana_linder@
tcenergy.com.
Any person or the Commission's staff
may, within 60 days after issuance of
the instant notice by the Commission,
file pursuant to Rule 214 of the
Commission's Procedural Rules (18 CFR
385.214) a motion to intervene or notice
of intervention and pursuant to section
157.205 of the regulations under the
NGA (18 CFR 157.205), a protest to the
request. If no protest is filed within the
time allowed therefore, the proposed
activity shall be deemed to be
authorized effective the day after the
time allowed for filing a protest. If a
protest is filed and not withdrawn
within 30 days after the allowed time
for filing a protest, the instant request
shall be treated as an application for
authorization pursuant to section 7 of
the NGA.
Pursuant to section 157.9 of the
Commission's rules, 18 CFR 157.9,
within 90 days of this Notice the
Commission staff will either: complete
its environmental assessment (EA) and
place it into the Commission's public
record (eLibrary) for this proceeding; or
issue a Notice of Schedule for
Environmental Review. If a Notice of
Schedule for Environmental Review is
issued, it will indicate, among other
milestones, the anticipated date for the
Commission staff's issuance of the EA
for this proposal. The filing of the EA
in the Commission's public record for
this proceeding or the issuance of a
Notice of Schedule for Environmental
Review will serve to notify federal and
state agencies of the timing for the
completion of all necessary reviews, and
the subsequent need to complete all
federal authorizations within 90 days of
the date of issuance of the Commission
staff s EA.
Persons who wish to comment only
on the environmental review of this
project should submit an original and
two copies of their comments to the
Secretary of the Commission.
Environmental commenters will be
placed on the Commission's
environmental mailing list and will be
notified of any meetings associated with
the Commission's environmental review
process. Environmental commenters
will not be required to serve copies of
filed documents on all other parties.
However, the non-party commenters
will not receive copies of all documents
filed by other parties or issued by the
Commission and will not have the right
to seek court review of the
Commission's final order.
The Commission strongly encourages
electronic filings of comments, protests
and interventions in lieu of paper using
the eFiling link at h ttp://www.fere -gov.
Persons unable to file electronically
should submit an original and 3 copies
of the protest or intervention to the
Federal Energy regulatory Commission,
888 First Street NE, Washington, DC
20426.
Dated: January 15, 2020.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
[FRDoc. 2020-00957 Filed 1-21-20; 8:45 am]
BILLING CODE 6717-01-P
ENVIRONMENTAL PROTECTION
AGENCY
[FRL-10004-61-OW]
Notice of Webinar Briefing and Public
Meeting
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Notice of webinar briefing and
public meeting.
SUMMARY: The EPA's Environmental
Financial Advisory Board (EFAB) will
hold a webinar briefing on January 30,
2020 and a public meeting on February
11-13, 2020 in Washington, DC. The
purpose of the webinar will be to
receive a background briefing on the
Backhaul Alaska program. The purpose
of the public meeting will be to:
Consider a report by the EFAB
Storm water Infrastructure Finance Task
Force Workgroup; conduct a
consultation with the EPA on financing
options for the Backhaul Alaska
program; receive briefings on other
environmental financing topics; and
consider possible future projects.
DATES: The webinar will be held on
January 30, 2020 from 1 p.m. to 3 p.m.
EST. The February 11, 2020 through
February 13, 2020 public meetings will
be held as follows: February 11 and 12,
2020 from 9 a.m. to 5 p.m. EST, and on
February 13, 2020 from 9 a.m. to 1 p.m.
EST.
ADDRESSES: The webinar briefing will be
conducted by webinar only and is open
to the public; interested persons must
register in advance at https://
register.got owebin ar.com/register/
2221546055725723395. The public
meeting will be held at the Washington
Marriott Georgetown, 1221 22nd Street
NW, Washington, DC 20037. The
meeting is open to the public; however,
seating is limited. All members of the
public who wish to attend the meeting
are asked to register in advance, no later
than February 5, 2020 at https://
efa bmeetingfeb2020. even tbrite.com.
FOR FURTHER INFORMATION CONTACT: Any
member of the public who wants further
information concerning the webinar
briefing or the public meeting may
contact Stephanie Sanzone, EFAB
Coordinator, via telephone/voice mail
(202) 564-2839 or email at
sanzone.stephanie@epa.gov. The EFAB
mailing address is: EPA Environmental
Financial Advisory Board (4204M), U.S.
Environmental Protection Agency, 1200
Pennsylvania Avenue NW, Washington,
DC 20460. General information about
the EFAB can be found on the EPA
website at https://www.epa.gov/
wa terfinancecen ter/efa b.
SUPPLEMENTARY INFORMATION:
Background: The EFAB is an EPA
advisory committee chartered under the
Federal Advisory Committee Act
(FACA), 5 U.S.C. App. 2, to provide
advice and recommendations to the EPA
on innovative approaches to funding
environmental programs, projects, and
activities. Administrative support for
the EFAB is provided by the Water
Infrastructure and Resiliency Finance
Center within the EPA's Office of Water.
Pursuant to FACA and EPA policy,
notice is hereby given that the EFAB
will hold a webinar briefing and a
public meeting for the following
purposes:
Webinar Briefing: The purpose of the
webinar on January 30, 2020 will be for
members of the EFAB to receive a
briefing on the Backhaul Alaska
program in preparation for a
consultation on the program to be held
at the February 11-13, 2020 public
meeting. Due to unforeseen
administrative circumstances, the EPA
is announcing this webinar with less
than 15 calendar days notice. The
webinar is open to the public, but no
oral public comments will be accepted
during the briefing. Written public
comments relating to the Backhaul
Alaska consultation should be provided
in accordance with the instructions
below on written statements.
Public Meeting: The agenda for the
meeting on February 11-13, 2020 will
include:
(1) Review of a report by the EFAB
Storm water Infrastructure Finance Task
Force Workgroup. Pursuant to Section
4101 of the America's Water
Infrastructure Act of 2018, the Task
Force was established under the
auspices of the EFAB to prepare a report
on the availability of public and private
sources of funding for the construction,
rehabilitation, and operation and
maintenance of stormwater
infrastructure. The final Task Force
report will be considered by the EFAB
for revision or approval for transmittal
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Federal Register/Vol. 85, No. 14/Wednesday, January 22, 2020/Notices
3679
to the agency. For additional
information on the work of the Task
Force, contact Ms. Ellen Tarquinio, EPA
staff lead, at tarquinio.ellen@epa.gov.
(2) Consultation on financing options
for the Backhaul Alaska program. In
2019, the EFAB prepared an advisory
report on revenue options for a waste
service backhaul program in rural
Alaska. At the request of EPA Region 10,
the EFAB has agreed to engage in
further discussions on financing and
governance options for the Backhaul
Alaska program. A consultation is a
form of advisory activity that provides
oral advice and feedback from the EFAB
members at a public meeting. For
additional information on the Backhaul
Alaska program, contact Ms. Gabriela
Carvalho, EPA Region 10, at
carvalho.gabriela@epa.gov.
(3) Briefings on environmental
finance topics. The EFAB will hear from
invited EPA representatives on issues
relating to financing of environmental
protection in small communities.
(4) Discussion of potential future
advisory topics. EFAB members will
discuss potential environmental finance
topics on which the Board may wish to
provide advice and recommendations to
the EPA.
Availability of Meeting Materials:
Briefing materials for the webinar and
materials for the February 11-13, 2020
meeting (including meeting agenda and
draft review documents) will be
available on the EPA website at https://
www.epa .gov! wa terfinancecen ter/efa b.
Procedures for Providing Public Input:
Public comment for consideration by
EPA's federal advisory committees has a
different purpose from public comment
provided to EPA program offices.
Therefore, the process for submitting
comments to a federal advisory
committee is different from the process
used to submit comments to an EPA
program office. Federal advisory
committees provide independent advice
to the EPA. Members of the public can
submit comments on matters being
considered by the EFAB for
consideration by members as they
develop their advice and
recommendations to the EPA.
Oral Statements: In general,
individuals or groups requesting an oral
presentation at EFAB public meetings
will be limited to five minutes. Persons
interested in providing oral statements
at the February 11-13, 2020 meeting
should contact Stephanie Sanzone in
writing (preferably via email) at the
contact information noted above by
February 5, 2020 to be placed on the list
of registered speakers.
Written Statements: Written
statements for the February 11-13, 2020
meeting should be received by February
5, 2020 so that the information can be
made available to the EFAB for its
consideration prior to the meeting.
Written statements should be sent via
email to efab@epa.gov (preferred) or in
hard copy with original signature to the
EFAB mailing address above. Members
of the public should be aware that their
personal contact information, if
included in any written comments, may
be posted to the EFAB website.
Copyrighted material will not be posted
without explicit permission of the
copyright holder.
Accessibility: For information on
access or services for individuals with
disabilities, or to request
accommodations for a disability, please
contact Sandra Williams at (202) 564-
4999 or williams.sandra@epa.gov at
least 10 business days prior to the
meeting to allow as much time as
possible to process your request.
Dated: January 13, 2020.
Andrew Sawyers,
Director, Office of Wastewater Management,
Office of Water.
[FRDoc. 2020-00980 Filed 1-21-20; 8:45 am]
BILLING CODE 6560-50-P
ENVIRONMENTAL PROTECTION
AGENCY
[FRL-10003-88-Region 6]
Notice of Availability of Final
Designation of Certain Stormwater
Discharges in the State of New Mexico
Under the National Pollutant Discharge
Elimination System of the Clean Water
Act
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Notice.
SUMMARY: The Regional Administrator
of the Environmental Protection Agency
Region 6 (EPA) is providing notice of
the availability of EPA's final
determination that storm water
discharges from the Los Alamos Urban
Cluster (as defined by the 2010
Decennial Census) and Los Alamos
National Laboratory (LANL) property
are contributing to violations of New
Mexico water quality standards (WQS)
and require National Pollutant
Elimination System (NPDES) permit
coverage under the Clean Water Act
(CWA). This action is in response to a
June 30, 2014 petition filed with EPA by
Amigos Bravos entitled "A Petition by
Amigos Bravos for a Determination that
Storm Water Discharges in Los Alamos
County Contribute to Water Quality
Standards Violations and Require a
Clean Water Act Permit."
DATES: EPA's Designation Decision and
Record of Decision in Response to
Petition by Amigo Bravos for a
Determination that Stormwater
Discharges in Los Alamos County
Contribute to Water Quality Standards
Violations and Require a Clean Water
Act Permit ("EPA's Decision
Document") was signed on December
16, 2019.
ADDRESSES: For further information
contact Ms. Evelyn Rosborough via
email: rosborough.evelyn@epa.gov, or
may be mailed to Ms. Evelyn
Rosborough, Environmental Protection
Agency, Water Division (6WQ-NP),
1201 Elm Street, Suite 500, Dallas, TX
75270.
SUPPLEMENTARY INFORMATION: EPA is
providing notice of availability of its
final determination that stormwater
discharges from MS4s located in the
portion of Los Alamos County within
the Los Alamos Urban Cluster (as
defined by the 2010 Decennial Census)
and on Los Alamos National Laboratory
(LANL) property within Los Alamos
County and Santa Fe County are
contributing to violations of New
Mexico water quality standards (WQS)
and require NPDES permit coverage.
EPA's final designation determination is
made pursuant to the authority of CWA
§ 402(p)(2)(E) and 40 CFR
122.26(a)(9)(i)(D) and 122.26(f)(2). CWA
§ 402(p)(2)(E) and 40 CFR 122.26
(a)(9)(i)(D) allow EPA to designate for
NPDES permit coverage stormwater
discharges that EPA determines are
contributing to violations of WQS, but
are not otherwise required to be
permitted under EPA's stormwater
regulations.
Details of EPA's final designation
determination are available in EPA's
Decision Document. EPA's Decision
Document and ancillary materials may
be viewed on the EPA Region 6 web
page at https://www.epa.gov/npdes/
epas-residual-designation-authority.
Issued on: Dated: December 16, 2019.
Ken McQueen,
Regional Administrator, U.S. Environmental
Protection Agency, Region 6.
[FRDoc. 2020-00981 Filed 1-21-20; 8:45 am]
BILLING CODE 6560-50-P
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-Agenda (as of 2/7/2020)-
U.S. Environmental Protection Agency
Environmental Financial Advisory Board
Public Meeting
Washington Marriott Georgetown
1221 22nd Street, NW, Washington, DC 20037
February 11-13, 2020
Tuesday, February 11
9:00 am I. WELCOME AND REVIEW OF AGENDA
Ed Chu, EFAB Designated Federal Officer
- Joanne Throwe, EFAB Chair
9:15 am II. DELIBERATION ON THE STORMWATER FINANCING TASK FORCE REPORT
A. Overview of Task Force Process, Findings and Recommendations (15 minutes)
- Joanne Throwe and Rudy Chow, Task Force Co-chairs
B. Section 4: Sufficiency of Funding (Charge Q3) (30 min)
- Section Lead: Ted Henifin
EFAB Lead Discussant: Yvette Downs
C. Section 5: Existing Sources of Funding (Charge Q1) (30 min)
- Section Lead: Pam Lemoine
EFAB Lead Discussant: William Stannard
10:30 am BREAK
10:45 am D. Section 6: Infrastructure Affordability (Charge Q2) (30 min)
- Section Lead: Ted Chapman
EFAB Lead Discussant: Craig Holland
E. Task Force Recommendations (Section 3) (30 min)
- Craig Holland
11:45 am LUNCH ON YOUR OWN
1:00 pm PUBLIC COMMENT ON STORMWATER FINANCING TASK FORCE REPORT
Registered Speakers
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1:15 pm
II. DELIBERATION ON THE STORMWATER FINANCING TASK FORCE REPORT (cont.)
F. Executive Summary (30 min)
- Joanne Throwe
G. EFAB Letter to the Administrator (15 min)
- Joanne Throwe
- Motion on Revisions (If Any)
2:00 pm H. Final Disposition (30 min)
- Motion to approve the report and letter
Discussion on the Motion
- Vote on the Motion
Next Steps
2:30 pm BREAK
3:00 pm III. UPDATE ON ACTIVITIES AT EPA-FUNDED ENVIRONMENTAL FINANCE CENTERS
(EFC)
Khristopher Dodson, Syracuse University EFC
- Medessa Burian, University of Maryland EFC
4:00 pm IV. UPDATE ON OPTIONS FOR EFAB REPORT LIBRARY/WEBSITE (30 min)
Ed Chu and EFAB Staff
4:45 pm RECESS
Ed Chu, EFAB Designated Federal Officer
2
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9:00 am RECONVENE
Ed Chu, EFAB Designated Federal Officer
- Joanne Throwe, EFAB Chair
9:15 am V. SMALL COMMUNITY ENVIRONMENTAL SERVICES RESILIENCY - PANEL DISCUSSION
David Lloyd, Director
EPA's Office of Brownfields and Land Revitalization
- Matthew Dalbey, Director
EPA's Office of Community Revitalizaton
- Matthew Tejada, Director
EPA's Office of Environmental Justice
- Al McGartland, Director
EPA's National Center for Environmental Economics
Barbara VanTil, Water Branch Chief
EPA's Office of Enforcement and Compliance Assurance
10:15 am BREAK
10:30 am V. SMALL COMMUNITY ENVIRONMENTAL SERVICES RESILIENCY- PANEL DISCUSSION
(cont.)
11:30 am LUNCH
1:00 pm VI. CONSULTATION ON FINANCING AND GOVERNANCE OPTIONS FOR BACKHAUL
OF HAZARDOUS WASTE FROM REMOTE ALASKA COMMUNITIES
- Summary of the Charge and Materials: Gabriela Carvalho, Region 10
- Small Group Discussions, With Report Outs and Rotations
Rapporteur/Notetaker Teams:
• Brent Anderson/Janice Beecher
• Chris Meister/David Zimmer
• Eric Rothstein/Jim McGoff
EFAB Discussion and Wrap Up
4:45 pm PUBLIC COMMENT ON BACKHAUL ALASKA
Registered Speakers
5:00 pm RECESS
Ed Chu, EFAB Designated Federal Officer
3
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Thursday, February 13
9:00 am RECONVENE
Ed Chu, EFAB Designated Federal Officer
- Joanne Throwe, EFAB Chair
9:15 am VII. PRESENTATION OF PROPOSED CHARGES FOR POTENTIAL EFAB PROJECTS (30 min
each)
A. Opportunity Zones
- EFAB Leads: (TBD)
- Agency Client: Office of Policy
B. Stormwater Credit Trading
EFAB Leads: Craig Holland, Ted Henifin
Potential Agency Client: Office of Water
10:30 am BREAK
10:45 am C. Water Affordability
EFAB Leads: Eric Rothstein, Ted Henifin
Potential Agency Client: Office of Water
D. Risk and the Cost of Capital
EFAB Leads: Jan Beecher, Ted Chapman, Ed Crooks, Richard Weiss
Potential Agency Client: TBD
11:45 am PUBLIC COMMENT ON PROPOSED CHARGES
Registered Speakers
12:00 pm NEXT STEPS AND MEETING WRAP-UP
Ed Chu, EFAB Designated Federal Officer
- Joanne Throwe, EFAB Chair
12:15 pm ADJOURN
Ed Chu, EFAB Designated Federal Officer
4
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Evaluating
Stormwater
Infrastructure
Funding and
Financing Task
Force
Workgroup under the
Environmental Financial Advisory Board
Draft Report
January 2020
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Contributing EFAB Members
Lori Beary
Ted Chapman ~
Rudy Chow *
Lisa Daniel
Yvette Downs
Ted Henifin ~
Craig Holland
Pam Lemoine ~
Chris Meister
Eric Rothstein
Angie Sanchez
Bill Stannard
Joanne Throwe *
* Co-Chairs
Section Leads
Invited Consultants
Bethany Bezak
Jerry Bradshaw
David Bulova
Janet Clements
Carrie Evenson
Matthew Fabry
Carol Haddock
Laurie Hawks
Lisa Kay
Drew Kleis
Prabha Kumar
Rebecca Losli
John Lundell
Ewelina Mutkowska
Fernando Pasquel
Mike Personett
Andrew Reese
Elizabeth Treadway
Chuck Walter
EPA Supporting Staff
Sonia Brubaker
Tara Johnson
Ellen Tarquinio
Britney Vazquez
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
» * #
/
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Table of Contents
1.0 EXECUTIVE SUMMARY 1
1.1 Stormwater Infrastructure Funding Task Force Report and Charge 1
1.2 Local Stormwater Funding Efforts 2
1.3 Federal Stormwater Funding Support 2
1.4 Recommendations 3
2.0 INTRODUCTION AND BACKGROUND 5
2.1 Stormwater Infrastructure Drivers—A New Paradigm 6
2.2 Challenges and Opportunities 7
2.3 Report Overview 8
2.4 Funding Needs Not Included in This Report 10
2.5 Key Terms 10
3.0 TASK FORCE RECOMMENDATIONS 13
3.1 Recommendation Categories 14
4.0 SUFFICIENCY OF FUNDING 21
4.1 American Support for Investments in Water Infrastructure (2019) 23
4.2 Black & Veatch Stormwater Utility Surveys (2016 and 2018) 23
4.3 Clean Watershed Needs Survey 2012 Reportto Congress (2016) 24
4.4 Florida Stormwater Association Stormwater Utility Report (2016 and 2018) 25
4.5 Georgia Stormwater Utilities Report (2017) 26
4.6 Southeast Stormwater Association Utility Report (2019) 26
4.7 The Chesapeake Stormwater Network Select Results of the MS4 Needs Survey (2016) 26
4.8 Water Environment Federation MS4 Needs Assessment Survey Results (May 2019) 27
4.9 Western Kentucky University Stormwater Utility Surveys (2013,2016,2018 and 2019) 27
5.0 EXISTING SOURCES OF FUNDING 29
5.1 The Role of the Federal Government in Funding Stormwater Programs 29
5.2 Stormwater Funding—Types and Uses of Funds 30
5.3 Availability of Funding 54
5.4 Barriers to Obtaining Funding 57
5.5 Summary of Existing Funding Sources 61
6.0 INFRASTRUCTURE AFFORDABILITY 63
6.1 Infrastructure Efficiency 63
6.2 Financial Capability 65
6.3 Customer Household Affordability 75
APPENDIX I: MUNICIPAL FINANCIAL REPORTING AND ASSET MANAGEMENT 77
APPENDIX II: CASE STUDIES 80
APPENDIX III: STORMWATER FUNDING DATABASE 112
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
m m $
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Acronym List
Acronym
AWIA
America's Water Infrastructure Act
BMP
Best Management Practice
CBP3s
Community-Based Public-Private Partnerships
CSO
Combined Sewer Overflow
CSS
Combined Sewer System
CWA
Clean Water Act
CWNS
Clean Watersheds Needs Survey
CWSRF
Clean Water State Revolving Fund
DWSRF
Drinking Water State Revolving Fund
EFAB
Environmental Financial Advisory Board
ERU
Equivalent Residential Unit
FCA
Financial Capability Assessment
FCI
Financial Capability Index
FEMA
Federal Emergency Management Agency
FSA
Florida Stormwater Association
~ HEAP
Low Income Home Energy Assistance Program
LTCP
Long Term Control Plan
MHI
Median Household Income
MS4
Municipal Separate Storm Sewer System
NFIP
National Flood Insurance Program
NPDES
National Pollutant Discharge Elimination System
O&M
Operation and Maintenance
P3
Public-Private Partnerships
PRI
Program-related Investment
Rl
Residential Indicator
SRF
State Revolving Fund
USACE
United States Army Corps of Engineers
USDA
United States Department of Agriculture
USEPA or EPA
United States Environmental Protection Agency
WEF
Water Environment Federation
WKU
Western Kentucky University
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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1.0 Executive Summary
Stormwater Funding: A National Problem That Requires Action
Effective stormwater management is as integral to American quality of life as effective wastewater
management and delivery of safe drinking water. Hence, stormwater management needs to be deemed
as a true utility service on par with drinking water and wastewater utility services —and it needs
equitable and reliable funding, just like drinking water and wastewater utilities.
In the United States, drinking water and wastewater management services, generally through the utility
structure, have matured to become reliable and effective services to the communities, and with
dedicated sources of funding. Cumulatively, Clean Water State Revolving Fund programs have provided
$133 billion in assistance, mainly in the form of low-cost financing, to a wide range of eligible borrowers.
The utility structure that is conducive to effective management and dedicated funding, which has
worked well in the drinking water and wastewater sectors, should be applied to stormwater, the next
frontier for this nation's water quality goals. But even a utility structure requires predictable and
adequate revenues and sound governance. If these two elements are in place, effective operational
capability will follow. Unfortunately, only 1,600 of the 7,550 permitted stormwater entities in the United
States have dedicated revenue sources, such as stormwater user fees (also known as stormwater
utilities where fees are based, for example, largely on impervious area), taxes, or established drainage
districts that collect dedicated funding for stormwater.
Stormwater knows no jurisdictional boundaries and crosses state, county and municipal borders. There
are no comprehensive assessments of the funding needed to construct, and adequately maintain and
operate stormwater infrastructure nationally. Recent regional, limited surveys estimate stormwater
management and infrastructure funding needs in the billions of dollars annually beyond current funding
levels. Without question, the challenges related to stormwater funding are daunting and there is a
pressing need to continue to improve estimates of the sector's needs. The dedicated stormwater
funding sources that do exist are typically insufficient for currently known stormwater needs. Given the
magnitude and cross-jurisdictional nature of the stormwater challenge, local funding efforts are not
enough. There is a need for federal investment in stormwater infrastructure, similar to the level of
investment that federal funding programs have provided in the past to begin building our interstate
highway system, upgrade our wastewater infrastructure, or deliver safe drinking water to our homes.
The federal financing and funding framework that has worked so well to support the drinking water and
wastewater sectors should be adapted to fund solutions to the stormwater challenge. This type of
federal financing and funding will support communities with stormwater permits that serve more than
80 percent of the U.S. population. Therefore, stormwater funding is a national problem that requires
action.
1.1 Stormwater Infrastructure Funding Task Force Report and Charge
This report was developed in response to Section 4101 of the 2018 America's Water Infrastructure Act
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
• • •
1
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(AWIA), which directed the Environmental Protection Agency (EPA) to establish a Stormwater
Infrastructure Funding Task Force "to conduct a study on, and develop recommendations to improve the
availability of public and private sources of funding for the construction, rehabilitation, and operation
and maintenance of stormwater infrastructure" to meet the requirements of the Clean Water Act.
Specifically, the Task Force was charged with the following tasks:
# Identify existing federal, state and local public and private sources of funding for stormwater
infrastructure (addressed in Section 5.0).
A Assess how the source of funding affects affordability, including costs associated with infrastructure
finance (addressed in Section 6.0).
i Assess whether these sources of funding are sufficient to support capital expenditures and long-
term operational and maintenance costs required to meet the stormwater infrastructure needs of
municipalities (addressed in Section 4.0).
1.2 Local Stormwater Funding Ehui
Finding funding sources has become a necessary activity for local governments and utilities that are
charged with managing stormwater programs. Several professional organizations have developed
publications and held workshops on how to develop and implement dedicated funding mechanisms.
Their advocacy efforts have also elevated the discussion on the need for funding and the importance of
affordability.
Perhaps more importantly, conversations in recent years have shifted from "how to develop stormwater
utilities" to the need for innovative funding strategies that include public-private partnerships,
incentives for private property owners to implement stormwater controls, green bonds, and trading
schemes. Innovative funding mechanisms, coupled with reliable traditional mechanisms (e.g.,
stormwater utilities, fees-in-lieu-of, drainage/taxing districts) provide local programs with additional
alternatives to fund their stormwater needs.
1.3 orri , Support
As previously stated, local funding efforts alone are not enough. Stormwater infrastructure requires
funding and it has been neglected, or inadequately funded, for far too long. There is a need for federal
investment in stormwater infrastructure, similar to the level of investment that federal funding
programs have provided in the past to, among other things, begin building our interstate highway
system, upgrade our wastewater infrastructure, and deliver safe drinking water to our homes.
The federal government can also help by allocating funding for stormwater programs from existing
related programs to ensure that infrastructure is properly maintained and that future infrastructure
planning, design and capital expenditures are conducted using industry best practices.
Municipalities and local utilities need federal and state help in defining long-term reliable funding
sources. Funding must be available in all states and be sufficient to support both capital expenditures
and long-term operation and maintenance costs.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
m m #
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1.4 Recommendations
Task Force recommendations are presented as items that are practical to implement, actionable at the
federal level and understandable to the public. They present suggestions to use existing funding
mechanisms, increase accessibility to those funding mechanisms, identify additional funding
opportunities, and enhance public education. The Task Force's recommendations are grouped into the
following categories:
§ Stormwater funding education and technical assistance. Educating the public and elected officials
on the need for stormwater funding is critical to the successful implementation of and community
support for funding solutions. In addition, many communities need technical assistance related to
evaluating and securing funding and financing mechanisms.
Recommendation: Educate elected representatives, professional administrative leaders and the
general public on the need for sustainable local stormwater funding and organizational capacity
through, for example, the creation of stormwater utilities or the expansion of existing utilities
into the stormwater sector.
Recommendation: Provide technical assistance and funding to help communities create
sustainable funding sources. This could include assistance with funding need assessments,
organization analysis, grant applications, and/or establishing a stormwater utility fee.
i Simplification and/or modification of existing federal grant and loan programs and affordability
support. Federal grants, loans (e.g., from State Revolving Funds) and support to enhance
affordability are needed to maintain sustainable local funding sources.
Recommend Provide for a common application for differ en t federal grants across all
' federal agencies.
The State Revolving Fund (SRF) is an integral tool among the many
infrastructure financing options available to communities. Whether stormwater receives
consideration of its own through a new SRF program, or receives less restrictive eligibility
considerations and larger appropriations within the existing Clean Water SRFs (CWSRF) or
eligible Drinking Water SRF (DWSRF) projects, it is the view of the Task Force that stormwater
would benefit from an additive - not zero-sum - recurring financial commitment from EPA. This
could be achieved by the implementation of one or more of the following, each of which is
outlined below:
o Create a new SRF program exclusive to stormwater programs and projects.
o Expand the existing Water Infrastructure Finance and Innovation Act (WIFIA) program or
fund the Army Corps of Engineers' Water Infrastructure Program also established in 2014.
o Create a specific stormwater set-aside in the existing CWSRF framework and increase
awareness/ guidance on the CWSRF for stormwater projects, including the Green Project
Reserve program.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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Recommendation: Use federal funding or technical assistance to help utility customers who are
financially struggling to pay their water, sewer, and stormwater utility bills (similar to Low
Income Home Energy Assistance Program (LIHEAP)).
# Dedicated federal stormwater funding assistance. Given the magnitude of the stormwater needs
described in this report, there is a need for federal investment similar to the investments in the
National Interstate Highway system and historical wastewater treatment plant upgrades.
Recommendation: Build comprehensive national database that enumerates state barriers to
implementation of new dedicated stormwater revenue sources such as user fees or other
revenue sources, and/or any state restrictions on existing fees and charges.
Recommendation: Increase annual funding allocation for and modify the 319(h) grant program
to allow and encourage local capacity building, utility fee study and implementation, asset
management, and remove restrictions on use of grant funds for MS4 permit compliance.
Recommendation: Develop a new construction grant program specifically for stormwater
projects, similar to the federal Municipal Construction Grants Program that funded the
construction of wastewater treatment plants.
Recommend Given the link between agricultural pollution and mandated stormwater
pollutant reduction targets for impaired streams, a Farm Bill Federal subsidy dedicated to
stormwater programs would also be valuable. Require 10 percent of US federal farm subsidies
(all programs) be re-directed toward stormwater/nonpoint impacts in same watershed where
recipient farm is located.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
m m #
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2.0 Introduction and Background
Stormwater management involves diverse activities that span both operations and maintenance (O&M)
and capital program. The O&M activities, to name a few, typically include the maintenance of
stormwater conveyance infrastructure; good housekeeping practices; land use development and
redevelopment permitting, monitoring, and inspections; public education and outreach; and
management of various other stormwater programs. The capital program management typically
includes asset management, capital projects planning and execution. Needless to say, holistic
management of stormwater O&M and capital program services requires sustainable and dedicated
funding.
Stormwater management is widely viewed as a key part of the solution to improving water quality in the
nation's waterways, reducing local flooding/drainage problems, and enhancing community resiliency.
However, the challenges related to funding stormwater infrastructure are daunting: the stormwater
sector is still maturing and has traditionally not been funded as a true "utility" operation like wastewater
and drinking water utilities. Meanwhile, EPA has identified urban stormwater runoff as the only major
growing source of water pollution across much of the country. Starting in the 1990s, EPA sought to
reduce pollution in U.S. waterways through regulations and a permit program under the Federal Water
Pollution Control Act, commonly known as the Clean Water Act (CWA). Communities with stormwater
permits include more than 80 percent of the
U.S. population—therefore, stormwater
funding is a national problem that requires
action.
There are no comprehensive assessments of
the funding needed to construct, maintain and
operate stormwater infrastructure nationally. Recent regional or limited surveys estimate stormwater
management and infrastructure funding needs in the billions of dollars, ranging from $3.3 billion over
the next 10 years in Florida alone 1 to $8.1 billion per year for only municipal separate storm sewer
system (MS4) permittee activities in the United States.2
EPA estimates that $150 billion is needed for stormwater infrastructure and program investments (MS4s
and combined sewer overflows) over the next 20 years.3 The needed investment in stormwater
1 Florida Stormwater Association. 2018. Stormwater Utility Report. https://www.florida-
stormwater.org/stormwater-utilitv-reportl
2 WEF Stormwater Institute. 2019. National Municipal Separate Storm Sewer System (MS4) Needs Assessment
Survey Results. https://wefstormwaterinstitute.org/wp-content/uploads/2019/08/MS4-Survey-Report-2019.pdf
3 U.S. EPA. 2016. Clean Watersheds Needs Survey 2012 Report to Congress EPA-830-R-15005.
https://www.epa.gov/sites/production/files/2015-12/documents/cwns_2012_report_to_congress-508-opt.pdf
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
• • •
5
Recent regional or limited surveys
estimate stormwater management and
infrastructure funding needs in the billions
of dollars
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infrastructure is similar to the level of investment that federal funding programs have covered in the
past to initiate construction of our interstate highway system or upgrade wastewater treatment plants.
Funding needs continue to expand as the stormwater sector faces increasing challenges related to
regulatory requirements, water quality degradation, flood risk reduction, community resilience, aging
infrastructure, and more. Many communities have no sustainable source of funding for stormwater
programs. In addition, increasing stormwater management costs at the local level exacerbate the
affordability challenges that many communities face. While a more detailed analysis is needed to fully
assess the funding need, it is widely acknowledged that the stormwater infrastructure sector cannot
fully address these challenges at current funding levels.
This report was developed in response to Section 4101 of the 2018 AWIA, which directed EPA to
establish a Stormwater Infrastructure Funding Task Force "to conduct a study on, and develop
recommendations to improve the availability of public and private sources of funding for the
construction, rehabilitation, and operation and maintenance of stormwater infrastructure" to meet the
requirements of the CWA. AWIA stipulates that the Task Force comprise representatives of federal,
state and local government and private entities (including nonprofit entities). Furthermore, EPA is
required to submit a report to Congress no later than 18 months after AWIA enactment describing the
results of the Task Force's study and resulting recommendations.
The Task Force was convened under an existing Federal Advisory Committee, the Environmental Finance
Advisory Board (EFAB). 14-members of the EFAB with experience and expertise in stormwater funding
and financing are on the Task Force. EPA also initiated an open nomination process to identify expert
consultants to advise and support the Task Force. EPA selected 19 consultants to address gaps in the
Task Force's expertise and ensure the Task Force could complete the required study and
recommendations within the stipulated timeframe. Task Force members, consultants and key EPA staff
who supported the preparation of this report are presented at the beginning of this report.
Task Force members and consultants participated in two in-person meetings and in regular telephone
conference meetings to conduct research, develop the study and identify associated recommendations
for consideration by EPA. EPA also solicited and integrated public input on stormwater funding through
seven public meetings held across the country in Florida, Massachusetts, Illinois, the District of
Columbia, Virginia, Georgia, and Washington.
2.1 Storrnv .. re Drivers—A New Paradigm
Before the 1990s, municipal stormwater management was driven mainly by one consideration: convey
stormwater away from our built environment. While federal regulations added a new focus on water
quality, the Task Force recognizes the need to consider both water quality and water quantity when
evaluating funding sources and needs. In fact, stormwater management is undergoing a significant
paradigm shift (Figure 1): local programs often have multiple responsibilities, including water quality,
water quantity, floodplain management, resilience planning and response, regulation of new and re-
development, multi-objective planning, ecosystem health, environmental, and increasing community
expectations. These responsibilities are relevant to stormwater management in recognition of the
broader public concern for infrastructure management and environmental stewardship.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
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Expanding Stormwater Drivers
Figure 1. Graphic representing the current stormwater management paradigm shift.
2.2 Challenges and Opportunities
This report identifies several potential sources of funding available to most municipalities (see Section
5.0). While the length of the list may imply that it is easy to fund stormwater management activities, the
opposite is true: the volume of options shows that there is no universal solution, and many types of
funding must be supplemented by a baseline revenue stream like that found in other municipal-level
utilities. Establishing such a baseline revenue stream for stormwater management programs—programs
that themselves are undergoing such a significant paradigm shift—is extremely challenging and faces
legal obstacles in many places. Garnering community support for an expanding program is difficult
enough. Asking a community to pay for it in the form of user fees or taxes is an even greater challenge.
A municipal stormwater program cannot be funded in a bureaucratic vacuum and in an environment
where the decision makers and the community are not fully aware of the benefits and challenges of
stormwater management. It can only succeed with the support of the local community and its elected
officials. One of the many barriers to gaining that support is the lack of public understanding about what
a stormwater program is and how it affects quality of life for the average citizen. Municipal stormwater
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
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programs have focused on infrastructure and environmental stewardship but have not always done an
effective job of explaining to the community and elected officials what they are and why they are
important.
At the same time, the Task Force has observed that municipalities differ significantly with respect to the
distribution of stormwater management and regulatory compliance responsibilities due to variations in
local and state institutional frameworks. Under a new and evolving paradigm, institutional frameworks
often lag behind the functional changes brought about by the new drivers. The distribution of
responsibilities can affect cost-effectiveness, funding and affordability, creating situations with
overlapping responsibilities and a shortage of accountability or leadership for program implementation.
In addition, providing technical assistance and public outreach/education to such a dispersed
community of stormwater managers and programs is a challenge.
While these challenges are daunting, they also represent opportunities to interact with and leverage
other public investments such as transportation, flood protection, public safety, recreation and other
cultural endeavors that fit within the new stormwater paradigm. Municipalities have made great strides
to integrate stormwater projects and programs into these other areas through multi-benefit projects.
But much more must be done to move the needle on the adequacy of stormwater funding.
In summary, the local government stormwater manager is faced with multiple, costly, sometimes
conflicting responsibilities across a wide spectrum of stormwater-related demands—often with little
dedicated funding to accomplish necessary tasks. About 60 percent of the stormwater permittees
indicate that their major challenge is the lack of funding or availability of capital for implementation of
stormwater programs and design, construction and maintenance of stormwater infrastructure.4
2.3 Report Ov
The Task Force was charged with the following tasks:
Identify existing federal, state and local public and private sources of funding for stormwater
infrastructure (Section 5.0).
Assess how the source of funding affects affordability, including costs associated with infrastructure
finance (Section 6.0).
Assess whether these sources of funding are sufficient to support the capital expenditures and long-
term operations and maintenance (O&M) costs required to meet municipalities' stormwater
infrastructure needs (Section 7.0).
The report is organized based on the findings associated with these tasks, as described below.
Section 3.0: Task Force Recommendations
Section 3.0 presents the Task Force's overall recommendations. The recommendations present
4 WEF Stormwater Institute. 2019. National Municipal Separate Storm Sewer System (MS4) Needs Assessment
Survey Results. https://wefstormwaterinstitute.org/wp-content/uploads/2019/08/MS4-Survey-Report-2019.pdf
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suggestions to enhance the use of existing funding mechanisms, increase accessibility to those funding
mechanisms, identify additional funding opportunities, and measures to enhance public education. The
Task Force's recommendations are grouped into three succinct categories:
i Stormwater funding education and technical assistance;
A Simplification of existing federal grant and loan programs and affordability support; and
~ Dedicated federal stormwater funding assistance.
Section 4,0: Sufficiency of Funding
Section 4.0 discusses the difficulty of assessing the capital and long-term O&M funding needed for
municipal stormwater infrastructure in the United States. This section also presents information from
several regional and national surveys that attempt to make these estimates and includes case studies of
stormwater funding challenges in more than a dozen communities across the country. Finally, Section
4.0 describes the reasons why the funding gap exists and continues to grow, as well challenges
associated with finding effective solutions to meeting stormwater funding needs.
Section 5,0: Existing Sources in
Section 5.0 describes the various types of plausible funding sources such as recurring and sustainable
sources, intermittent revenue sources, capital financing sources and one-time sources of funding for
stormwater programs. Even though there are multiple types of funding sources, only a few can provide
reliable, sustainable, and dedicated revenue for holistic stormwater management. Perhaps more
importantly, without elected officials' support, to develop such dedicated sources of funding where it
currently doesn't exist, the availability of funding will continue to be limited, leaving most programs
without enough funds to meet all the stormwater community's needs.
Sect
Section 6.0 describes how available funding sources and financing options affect three aspects of a
municipality's stormwater management that are directly impacted by the various types of funding and
financing sources. The three aspects that this section focuses on are:
A Effective management of Infrastructure. Industry best practices, such as adopting proactive asset
management, leveraging resources and economies of scale, building resilience, and engaging in risk
mitigation, all of which can also improve affordability.
A Financial capability, is defined as the adequacy of a municipality's funding to meet its annual
stormwater O&M obligations and to manage its capital stormwater infrastructure needs,
determined based on delivering adequate levels of service. This sub-section discusses the impact of
different funding sources on building financial capacity and provides criteria for evaluating the
affordability impacts of different recurring, intermittent and one-time funding sources to address
capital and O&M requirements.
A Customer household affordability, defined as the impact that the various types of financial
resources have on the users of the system. This sub-section describes traditional and emerging
concepts that are used to evaluate household affordability.
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Affordability can also be impacted by the public and elected officials' lack of understanding of the need
for stormwater services and the benefits of stormwater programs. Therefore, the Task Force concludes
that educating these stakeholders can facilitate the implementation and acceptance of reliable and
sustainable funding sources.
2.4 Funding Needs Not Included in This Report
This report does not address funding needs related to the following programs or activities (which can
complement the goals of local stormwater management programs, but are typically funded by other
federal or local sources):
i Addressing agricultural water pollution. Most local stormwater programs focus on urban areas and
the associated drainage, flooding, resilience and stormwater quality needs. These local programs
typically do not have legislation that allows them to regulate agricultural activities. Soil and Water
Conservation Districts and other U.S. Department of Agriculture programs under the Farm Bill, as
well as CWA nonpoint-source regulations, address this growing source of pollution.
i Flood risk identification and mapping. Costs associated with the Federal Emergency Management
Agency (FEMA) flood risk identification and mapping program under the National Flood Insurance
Program (NFIP) are not included in this report, since these federal activities are funded by the NFIP
and flood insurance policy fees.
* Large flood risk management and ecosystem restoration programs. Large programs to address
riverine flooding navigation, and ecosystem restoration programs conducted by the U.S. Army Corps
of Engineers and funded through the Water Resources Development Act are not included in this
report. In some instances, local stormwater revenue is used as the local match for these large
projects, but the bulk of the costs are paid by federal sources.
2.5
To frame and further refine the scope of the required study, the Task Force first agreed on a definition
for stormwater, as well as definitions of associated environmental, technical and other considerations
and drivers for stormwater services. The Task Force also determined what considerations fall outside
the scope of the AWIA charge and are not addressed in this report.
The Task Force used the following key definitions related to stormwater, stormwater services and
regulatory requirements for municipal stormwater services:
§ Municipal stormwater: Surface water runoff, snow melt runoff, and drainage from public and
private lands in urban areas, typically collected in MS4s consisting of drains, pipes, catch basins,
outfalls, and ditches and conveyed to nearby streams, rivers, lakes, estuaries, basins, wetlands and
oceans, carrying with it a variety of urban pollutants.5 Stormwater control measures (e.g.,
basins/ponds and green infrastructure—bioswales, filters, infiltrators, pollutant traps, etc.), also
5 Adapted from National Association of Flood and Stormwater Management Agencies. 2006. Guidance for
Municipal Stormwater Funding, https://www.epa,gov/sites/production/files/2! iocuments/guidance-
manual-version-2x-2 O.pdf
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known BMPs, are used to "treat" municipal stormwater by capturing pollutants to improve water
quality and reducing runoff to prevent flooding.
A Municipal Separate Storm Sewer System (MS4): A conveyance or system of conveyances (including
roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, artificial
channels or storm drains) that is owned or operated by a state, city, town, borough, county, parish,
district, association or other public body and is designed or used to collect or convey stormwater,
but is not a combined sewer and is not part of a publicly owned treatment works (POTW).sThere
are 7,550 MS4 stormwater permittees in the United States, including more than 6,500 cities.
Communities with MS4 stormwater permits serve more than 80 percent of the U.S. population or
approximately 263 million people.7
~ Phase I Municipal Stormwater Regulation (hereafter Phase I): a 1990 regulation that requires
medium-sized and large cities, or certain counties with populations of 100,000 or more, to obtain
National Pollutant Discharge Elimination System (NPDES) permit coverage for their stormwater
discharges. There are about 855 Phase I MS4s covered by 250 individual permits.7
i Phase II Municipal Stormwater Regulation (Phase II): a 1999 regulation that requires small MS4s in
U.S. Census Bureau-defined urbanized areas, as well as MS4s designated by the permitting
authority, to obtain NPDES permit coverage for their stormwater discharges. Phase II also includes
non-traditional MS4s such as public universities, departments of transportation, hospitals and
prisons. There are about 7,000 Phase II MS4s covered by statewide General Permits; some states
instead use individual permits.8
A Combined Sewer System (CSS): A system of conveyance that carries and conveys both sanitary
sewage and stormwater flows, in the same pipe, to a POTW. CSSs serve about 43 million people in
about 1,100 communities nationwide.9
A Infrastructure efficiency: The ability to effectively manage the stormwater system infrastructure
and improve affordability through best management practices, including adopting proactive asset
management, leveraging resources and economies of scale, building resilience, and engaging in risk
mitigation.
# Integrated planning; A voluntary approach to meeting multiple Clean Water Act requirements by
identifying efficiencies from formerly distinct drinking water, wastewater and stormwater programs
and sequencing investments to address the highest priority projects first. Integrated planning also
encourages multi-benefit, cross-sector sustainable and comprehensive solutions to water resource
challenges.
6 Definition from 40 CFR § 122.26.
7 U.S. EPA. 2019. Stormwater Discharges from Municipal Sources. httpsi//www,epa,gov/npdes/stormwater-
discharges-municipal-sources
8 Ibid.
9 U.S. EPA. 1997. Combined Sewer Overflows—Guidance for Financial Capability Assessment and Schedule
Development. EPA 832-B-97-004. February 1997. https://www3.epa,gov/npdes/pubs/csofc.pdf
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i Median Household Income (MHI): The middle-income level earned by households in a given area,
intended to represent the economic status of households in that area. Fifty percent of households in
the specified area will earn above median household income, and 50 percent will earn below.
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3.0 Task Force Recommendations
The Task Force offers recommendations on how existing funding can be used and made more accessible,
as well as on identifying additional funding opportunities. They are intended to be actionable and
understandable to the public. The recommendations are summarized in the Executive Summary and
presented in detail below.
The Task Force's recommendations fall into the following categories:
* Stormwater funding education and technical assistance. Educating the public and elected officials
on accepting the need for stormwater funding is critical to the successful implementation of and
community support for funding sources. In addition, many communities need technical assistance
related to evaluating and securing funding and financing mechanisms.
* Simplification of existing federal grant and loan programs and affordability support. Federal
grants, loans (e.g., from State Revolving Funds) and support to enhance affordability are needed to
maintain sustainable local funding sources. These actions would provide communities an incentive
to create dedicated funding sources to demonstrate financial capacity and capabilities, while still
retaining the flexibility and local control as to the actual method for repayment.
* Dedicated federal stormwater funding assistance. Given the magnitude of the stormwater needs
described in this report, there is a need for federal investment similar to the investments in the
National Interstate Highway system and wastewater treatment plant upgrades. A Farm Bill Federal
subsidy dedicated to stormwater programs would also be valuable, given the link between
agricultural pollution and mandated stormwater pollutant reduction targets for impaired streams.
Several of the recommendations include direct involvement and interaction by EPA with state and local
agencies. The main goal is for federal actors to help state and local agencies, but the federal actors will
also learn about issues and barriers that confront local agencies. This two-way flow of information and
experiences will help bridge the gap between the source of clean water regulations (federal) and the
most important source of funding (primarily local). This, in turn, will also greatly benefit the overall goals
of the CWA, the involved agencies, and the public at large.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
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3.1 Recommendation Categories
3.1.1 Stormwater funding education and technical assistance
Recommendation: Educate elected officials, professional administrative leaders and the public
on the need for sustainable local stormwater funding and organizational capacity through, for
example, the creation of stormwater utilities or the expansion of existing utilities into the
stormwater sector. Sustainable funding for stormwater infrastructure builds long-term financial
capacity, improves operational performance—and over time produces results for citizens and
residents. For over two hundred years, this has been the experience with drinking water and
wastewater utilities in this country. The educational goals for these three audiences will
demonstrate that stormwater management investment directly benefits the health, safety and
economic opportunity for citizens and residents through the overall improvement of water
quality.
Stormwater, along with drinking water and wastewater, must be approached as part of a
comprehensive "One Water" solution. When stormwater management, sustainable drinking water
supplies and wastewater treatment resources and goals are aligned, communities avoid costs, are
financially sustainable, are safer, are better environmental stewards, and provide better economic
opportunities and quality of life for their residents. FEMA's own hazard mitigation program generally
notes that investments in key stormwater infrastructure alone improve a community's resilience; the
return on investment is four times or even better, through cost avoidance and quicker return to
normalcy than a do-nothing scenario.
Communities with successful water resource management strategies have generally identified financial
needs over multi-year planning horizons. Implementation of "One Water" strategies supported by
appropriate financial resources provide better management of public health, safety, economic and
financial risks. Successful education will help reduce barriers, such as those that may exist under state
law, and will build support to establish forward-looking and sustainable operational capability in
stormwater management and responsible and long-term finance and capital planning. The Task Force
Recommends that EPA's Water Finance Center work with other EPA programs and Federal Agencies to
address this recommendation.
Recomm Provide technical assistance and funding to help communities create
sustainable funding sources. This could include assistance with funding need assessments,
organization analysis, grant applications, and/or establishing a stormwater utility fee.
Many communities would be willing to work toward greater funding self-sufficiency but lack the
support, expertise and initial resources to get started. Federal assistance can help overcome these
hurdles through technical assistance and funding to support the initial activities necessary to create
sustainable funding sources.
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Technical assistance may include guidance documents, webinars, hands-on training and support. While
technology should be leveraged to make this assistance accessible to all communities with stormwater
issues, the technical assistance also needs to be proactive. Proactive programs should include reaching
out to smaller communities through circuit-rider-type programs with onsite assistance. This technical
assistance program could be established under the EPA Office of the Municipal Ombudsman established
by AWIA Section 5006.
EPA should provide funding and in the form of grants or matching funds to support the utility capacity
building, feasibility/needs assessment, grant applications and other activities needed to create
sustainable funding sources.
3,1,2 Simplification of existing federal g ms and affordability
support
I Recommendation: Provide for a common application for differ en t federal grants across all
federal agencies.
Most of the U.S. population lives in large urban or suburban areas, generally associated with
governmental units that have relatively more financial, technological and human resources. While these
areas are generally associated with governmental units that have relatively more financial, technological
and human resources, they do not always have sufficient resources to dedicate to securing necessary
stormwater funding. In addition, most individual local governments are associated with small or very
small populations (10,000 or fewer people). These communities are also often rural and often exhibit
below-average income indicators. As such, they may face particular difficulty in accessing the requisite
technical expertise and financial resources that are often needed to even apply for federal grants.
The Task Force believes all communities, especially small, rural and otherwise disadvantaged ones,
would greatly benefit from more uniformity to the federal grant application process—perhaps some
baseline commonality to all applications across the federal government irrespective of the agency or
department ultimately administering the grant program. A common application could lessen barriers for
communities if as much of the actual application as possible were exactly the same and not specific to
any particular federal agency or department. The Task Force notes that the federal Paperwork
Reduction Act (44 U.S.C. §§ 3501-3521) was established in 1980 but has not been amended since 1995,
during the infancy of the Information Age. For a comparable example, The Common App10, implemented
almost a generation ago, is now used by nearly 900 colleges and universities across all 50 states,
benefitting more than a million prospective college students. This streamlining and simplification saves
both the applicant and the associated higher education institutions significant time while breaking down
barriers of access and relieving burdens of redundancy.
10 The Common App is a college admissions application that applicants may use to apply to various universities.
More information available at: https://www.commonapp.org/.
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Recommendation: The SRF is an integral tool among the many infrastructure financing options
available to communities. Whether stormwater receives consideration of its own through a new
SRF program or receives less restrictive eligibility considerations and larger appropriations within
the existing SRFs, it is the view of the Task Force that stormwater would benefit from an additive
- not zero-sum - recurring financial commitment from EPA. These would provide communities an
incentive to create dedicated funding sources to demonstrate financial capacity and capabilities,
while still retaining the flexibility and local control as to the actual method for repayment. This
could be achieved by the implementation of one or more of the following, each of which is
outlined below with the associated risks and opportunities:
I. Create a new SRF program exclusive to stormwater programs and projects.
o Advantages
¦ Replicates programs that have been proven successful for decades.
¦ Would eliminate 'competition' with wastewater projects inherent within the
current CWSRF program.
o Disadvantages
¦ Would require the creation and passage of new enabling legislation to establish
a new SRF program.
II. Expand the existing WIFIA program (e.g. explicit references to stormwater project
eligibility, priority points for stormwater projects, lower project minimums for bundled
stormwater projects) allowing funding for more stormwater projects, or fund the Army
Corps of Engineers' Water Infrastructure Program also established in 2014.
Advantages
¦ Would not require new enabling legislation.
¦ WIFIA has already demonstrated the ability to leverage federal dollars many
times over the initial appropriation.
¦ The Corps' program has a stated mission to "enable local investments in projects
that enhance community resilience to flooding, promote economic prosperity
and improving environmental quality" which is already consistent with the
general aim of stormwater infrastructure.
o Disadvantages
¦ Bundling enough projects together to meet the scope of the WIFIA program.
¦ Administrative difficulty in successfully applying to the program.
III. Create a specific stormwater set-aside in the existing CWSRF framework and increase
awareness/ guidance on the CWSRF for stormwater projects, including the Green
Project Reserve program.
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o Advantages
¦ Would not require new federal legislation.
¦ Preserves each states' ability to administer the program to maximize efficiencies
and effectiveness specific to each states' needs.
o Disadvantages
¦ Might not improve best management practices or capability of communities if
the set-aside is viewed by them as an implicit high likelihood/guarantee to get
funded.
IV. Create a "One Water" SRF with equal weighting among drinking water, clean water
and stormwater.
o Advantages
¦ Would encourage community creativity and holistic, multi-year master planning
- including resilience and integrated planning - by way of multi-purpose projects
that achieve goals aligned with the One Water principles.
¦ Might be more likely to attract private sector participation, especially if flood
control and stormwater facilities are added as a private activity bond category
as proposed by the Administration in February 2018's infrastructure stimulus.
¦ Would provide communities an incentive to create dedicated funding sources to
demonstrate financial capacity and capabilities, while still retaining the flexibility
and local control as to the actual method for repayment.
o Disadvantages
¦ Would require amending existing enabling SRF legislation.
¦ The CWSRF has been in place since 1987 and the DWSRFsince 1997; therefore
decades of policy and administrative inertia could pose an implementation
barrier.
Ji m: Create federal funding and technical assistance (similar to LIHEAP) to help
address household affordability issues of utility customers who are economically challenged in
paying their water, sewer; and stormwater utility charges.
One of the strengths of the utility fee approach, to funding stormwater management, is that the cost of
services is distributed to properties in proportion to the stormwater that properties contribute to a
public stormwater system. This type of industry accepted fee for service approach is perceived to enable
equitable cost recovery by establishing a reasonable nexus between the demand placed on the system
and the charges that are assessed. However, the addition of a stormwater user fee, however small the
fee maybe, could create an additional burden on low-income households, including the elderly on fixed
incomes, that already struggle to pay the water and sewer utility charges.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
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To address household affordability challenge, some local governments have established customer
assistance programs to help with water, sewer, stormwater utility fees, using general funds or other
non-utility resources. However, at the local level, particularly in financially stressed communities,
establishing fee assistance programs becomes burdensome, even if statutes allow such
programs. Further, subject to varying State and Local statutes, many utilities are unable to establish any
low-income customer assistance programs, as establishing utility fee assistance programs using utility
enterprise funds, is deemed to violate the fee for service concept. Due to these types of challenges,
elected officials in many communities in the US are reluctant to adopt a stormwater utility fee funding
mechanism.
The federal LIHEAP11, in place since the 1980s, helps qualifying households offset a portion of their
energy costs. Expanding LIHEAP, with additional funding, to help offset water, sewer, stormwater utility
charges and/or establishing a similar distinct federal assistance program for water/sewer utilities,
including stormwater, could remove a major barrier to the creation of dedicated user fee-based
stormwater funding, at the local level.
3.1,3 Dedicated federal stormwater' ce
I Recommendation: Build comprehensive national database that enumerates state barriers to
implementation of new dedicated stormwater revenue sources such as user fees or other
revenue sources, and/or any state restrictions on existing fees and charges.
As part of 2020 Clean Watersheds Needs Survey, EPA should create a state-level funding evaluation
framework and request that states use that framework to identify barriers/gaps in state enabling
legislation to create new stormwater user fees and/or restrictions on fee increases. Once information is
received from states, EPA should post a compendium of findings from the evaluation in a publicly
available forum and provide educational materials for local government officials and the public. Further,
Congress should develop an incentive framework (e.g., matching 319 funds or other federal grant or
funding mechanisms) to encourage removal of state-level funding barriers, where applicable.
Increase annual funding allocation for and modify the 319(h) grant program
to allow and encourage local capacity building, utility fee study and implementation, asset
management; remove restrictions on use of grant funds for MS4 permit compliance.
The 319(h) grant program is an important resource to many small and medium-sized local governments,
but current allocation levels cannot meet demand. Increasing allocations will address critical needs at
the local level. The use of the funds for general operational program costs is limited to 10 percent. The
allocation, distributed to state nonpoint-source pollution programs, varies from year to year based on
budget authorizations. Therefore, there is no stable platform for grant awards at the local level. There is
a need to provide more funding support in an entire watershed, prioritized on financial capacity. Smaller
surface water management systems and systems in disadvantaged communities have limited capacity to
11 Low Income Home Energy Assistance Program (LIHEAP). US Department of Health and Human Services. More
information available at: https://www.acf.hhs.gov/ocs/programs/liheap
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address water quality protection challenges. Investment in capacity building through technical, financial
and managerial support, directly by consultation or through use of grant funds, is of critical importance.
Expanding the programmatic criteria for use of Section 319 Grants to address technical, managerial and
financial deficiencies, along with comprehensive asset management technical and funding support, will
advance local communities' ability to effectively carry out their role in partnership with federal
permitting, state program guidance and local surface water system operation. The current program
structure does not allow the use of these grant funds for MS4 permit compliance and consideration
should be given to allow for such use, specifically targeted to allow an exception for communities with
limited capacity to address water quality protection.
Recommendation: Develop a new construction grant program specifically for stormwater
projects, similar to the federal Municipal Construction Grants Program that funded the
construction of wastewater treatment plants.
A Stormwater Construction Grants Program, similar to the Municipal Construction Grants program that
funded the construction of wastewater treatment plants in the 1970's and 80's, could be developed to
serve as a much-needed jump start to investment in stormwater infrastructure/capital investment. Such
a program could likely be managed through existing SRF programs if new funding sources are identified.
However, funding stormwater management is less straightforward than funding construction of
wastewater treatment plants. The program components outlined below could help to avoid some of the
challenges of the original Municipal Construction Grants Program and better tailor a program to
stormwater management.
i The program could require participants to demonstrate capacity or secure financial assurances to
show that they can fund ongoing O&M for grant-funded projects. The technical assistance model
recommended by this Task Force could be used to help evaluate and provide these assurances.
§ In many communities, the greatest capital investment need is related to the renewal and/or
replacement of existing stormwater infrastructure. However, communities have indicated a need for
help in prioritizing stormwater asset maintenance and replacement and estimating associated
costs. To help meet this need, the construction grant program could fund development of an asset
management plan (or require communities to have one in place that meets certain requirements) as
a first tier of funding for renewal/replacement projects.
~ The grant program could require, prioritize or set aside a separate "bucket" of funds for
regional/watershed projects that result in cost savings and greater environmental benefits and help
avoid conflicts associated with implementing different methods for stormwater management across
communities. Similarly, the program could prioritize cross-sector opportunities, such as partnerships
with transportation departments, that result in significant cost savings and/or bring additional
matching funds.
12 WEF Stormwater Institute. 2019. National Municipal Separate Storm Sewer System (MS4) Needs Assessment
Survey Results. https://wefstormwaterinstitute.org/wp-content/uploads/2019/08/MS4-Survey-Report-2019.pdf
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i The program should not require "shovel-ready projects" and should fund design, feasibility, and
other upfront costs, particularly for small and medium-size communities.
A To further encourage participation of small and medium-size communities, particularly those that
are economically disadvantaged, the program could waive or reduce matching fund requirements. It
should also carefully evaluate the needs of these communities and set aside appropriate funds or
tailor the program to better meet their needs.
i The program should fund a wide range of projects and prioritize projects that result in the greatest
financial, environmental, and social benefits. Water quantity projects (flood control and mitigation)
should be eligible and be prioritized in consideration of all benefits—not subordinated to water
quality projects.
~ Many stormwater projects result in multiple benefits, particularly green infrastructure projects. The
grant program could be linked to other federal programs that provide funds for investment in
projects or programs related to these co-benefits (e.g., public health, air quality, energy savings,
economic development). For example, for projects that result in specific co-benefits, related federal
grant programs could provide the recipients' matching fund requirements. This would incentivize
these projects and stretch public dollars toward meeting multiple goals. It would require research
and coordination across relevant programs. This could also be achieved, in part, through the
common application for relevant federal grant programs/agencies, as recommended by this Task
Force.
Recommendat" Require 10 percent of U.S. federal farm subsidies (all programs) to be
redirected toward stormwater/nonpoint impacts in the same watershed as the recipient farm.
Agricultural lands in watersheds throughout the United States are major contributors to water quality
impairments from nutrient, sediment and bacteria runoff from farms and fields. The agricultural sector
has made great strides in implementing best management practices on farms but these practices have
limitations. Additionally, many of the most effective practices require taking land out of production, at
the same time as worldwide demand for food grows. Federal farm subsidies total about $20 billion per
year. Dedicating 10 percent to stormwater programs would generate nearly $2 billion annually for
stormwater program funding. Limiting eligibility to programs within the same watershed would provide
a rational connection between the funding source and the benefitting watershed.
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4.0 Sufficiency of Funding
Evaluate whether sources of funding are sufficient to support capital
expenditures and long-term operation and maintenance costs necessary to
meet the stormwater infrastructure needs of municipalities.
Determining the extent of capital and long-term O&M costs necessary to meet the stormwater
infrastructure needs of municipalities in the United States is a challenging task. Many surveys and
studies have been conducted over the past 30 years, each with its own limitations. The surveys and
studies presented below were largely developed within the last four years and represent only a few
resources from the pool. However, these resources collectively indicate the following:
* The needs are great and the funding gap is very wide—estimated to approach $10 billion annually.
* There are no large-scale, comprehensive, nationally representative numbers on total stormwater
capital and O&M needs.
* The most recent attempt to estimate the need on a national scale was conducted by the Water
Environment Federation's Stormwater Institute in 2018, with a survey of MS4 permittees that
determined the total annual funding gap for stormwater programs (MS4 compliance activities only)
to be $8.1 billion nationally.
* Other existing surveys evaluated and summarized below have estimated needs ranging from:
o A combined $1.7 billion for the next five years and $3.3 billion for the next 10 years for 137
stormwater utilities in Florida alone.13
o An EPA-estimated total of $19.2 billion for the nation over five years.14
o $9.7 billion for capital improvement over 20 years for 67 stormwater utilities in the
southeastern United States.15
The limitations of these and other surveys are discussed below and point to a potentially significant
underrepresentation of total national need. Many communities have not been able to quantify their
long-term needs or quantifying existing spending /annual revenues, which limits the ability to fully
capture funding needs.
* Needs specific to O&M are even less well captured and defined because O&M responsibilities in
many communities are passed to property owners or homeowner's associations where the
13 Florida Stormwater Association. 2018. Stormwater Utility Report. https://www.florida-
stormwater.org/stormwater-utilitv-reportl
14 U.S. EPA. 2016. Clean Watersheds Needs Survey 2012 Report to Congress EPA-830-R-15005.
https://www.epa.gov/sites/production/files/2015-12/documents/cwns_2012_report_to_congress-508-opt.pdf
15 WEF Stormwater Institute. 2019. National Municipal Separate Storm Sewer System (MS4) Needs Assessment
Survey Results. https://wefstormwaterinstitute.org/wp-content/uploads/2019/08/MS4-Survey-Report-2019.pdf
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stormwater systems or treatment facilities (best management practices or stormwater control
measures) are located.
A Revenue for established stormwater programs may be largely generated from taxes or user fees,
which can vary significantly across the country, and capital improvements may be more commonly
cash-financed than debt-financed.
~ In some communities, there is a moderate to significant gap between annual revenue and capital
and O&M needs, and lack of funding and financing is a significant concern and priority for
stormwater programs/utilities.
§ Public perception of water infrastructure, including stormwater infrastructure, varies widely across
the country and in each community. In some communities there is widespread support for investing
in the water infrastructure, even if this requires moderate increases in customer charges; other
communities oppose any increase in charges.
The Task Force has clearly identified the need for a national survey of stormwater needs that includes all
costs related to managing stormwater, from water quality to flood control. The American Society of Civil
Engineers, in coordination with the Water Environment Federation's Stormwater Institute, has been
preparing report cards on the nation's infrastructure since 1998 and in the next report card will add
stormwater infrastructure as a specific category. Until that time and lacking a national measure of the
need, the Task Force believes—based on the many existing surveys on stormwater funding needs—that
the funding gap is well into the billions of dollars per year and will continue to grow if things are left on
the current course.
In addition to a review of available surveys and estimates on a broad scale, Task Force members
developed illustrative case studies of stormwater programs in more than a dozen communities across
the country (Appendix II). While not meant to be statistically representative of stormwater programs
across the nation, these case studies highlight the funding challenges faced by both large metropolitan
communities like Atlanta, Chicago and San Diego and smaller communities like Coralville, Iowa; Griffin,
Georgia; and Washtenaw County, Michigan. In nearly all these communities, significant gaps exist
between current funding levels for annual O&M programs as well as capital investment needs.
Stormwater programs align their level of service with available funding, not typically with an asset-
management-generated, data-supported program ensuring adequate maintenance levels are achieved
and adequate investment is being made in renewal and replacement of stormwater infrastructure.
Some communities acknowledge that their current programs do not address the impact of more
intense, more frequent storms and floods. These case studies can be found in Appendix II.
There are many reasons the funding gap for stormwater infrastructure exists. While there are many
federal funding programs—including the revolving loan programs, WIFIA, the various Department of
Agriculture programs, and others—the total available falls well short of the need and access can be
challenging, especially for small and disadvantaged communities. Attracting private capital continues to
be challenging, as the expected return for third party capital is mismatched with the risk profile of most
stormwater projects. Without low-cost concessionary debt, there is no compelling desire for outside,
private capital to invest.
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The gap also does not appear to be related purely to affordability. Communities across the nation have
implemented local stormwater fees that, in isolation, do not create undue financial burdens on the
majority of their customers. Affordability is, however, an issue for lower-income segments of the
population across the nation: without a safety net to ensure they can get relief from rising water costs
(for all water including drinking water, wastewater and stormwater), it will be impossible to close the
gap with local fees alone.
Perhaps the biggest obstacle to closing the stormwater funding gap is the lack of political will to increase
revenues dedicated to stormwater investment at the local, state and federal levels. Without leadership,
stormwater infrastructure investment will continue to fall short of annual needs and future generations
will be burdened with failing stormwater systems.
A detailed summary of the resources and surveys evaluated to assess the funding gap is provided below.
4.1 American Support for Investme iter Infrastrut 019)
In February 2019, as part of the U.S. Water Alliance's Value of Water campaign, public opinion
researchers conducted a phone-based survey of 1,000 voters in 47 states (all but Hawaii, Oklahoma and
West Virginia). The goal of the campaign was to raise awareness of the importance of water and water
challenges facing the nation. This survey focused broadly on water infrastructure through the lens of
drinking water and wastewater infrastructure and did not include an explicit stormwater component.
Of the 1,000 respondents, 79 percent ranked rebuilding America's infrastructure as "extremely to very
important," which is consistent with information gathered during similar 2017 and 2018 surveys. In
2019, 83 percent of respondents rated the water infrastructure in their local communities as "very
good" or "somewhat good" (on par with 2016 responses, accounting for reported margin of sampling
error). However, only 49 percent of respondents rated the condition of the nation's water infrastructure
as "very good" or "somewhat good," while 36 percent believe it is "somewhat bad" or "very bad."
While public opinion of the condition of water infrastructure in their own communities remains positive,
nearly four in five respondents indicated that they support developing plans to rebuild America's water
infrastructure and support an increase in federal investment to do so. Of note, 80 percent of
respondents indicated that their drinking water and wastewater rates were affordable and would be
willing to pay a modest amount more to improve local water infrastructure. Additionally, two-thirds of
surveyed voters believe that investments in comprehensive upgrades, replacements and improvement
should be made today, rather than addressed over time as the need arises. The survey did not
distinguish between investments in capital improvements and O&M.
4.2 Black & Veatch Stormwater Utility Surveys (2016 and 2018)
National consulting firm Black and Veatch has been conducting biennial stormwater utility surveys for
over 25 years. The 2016 online survey included 74 participants from 24 states. The 2018 online survey
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included 75 participants from 21 states.16 Combined, the survey included local utilities that served
populations from 86 to 1.5 million people. Respondents to the 2018 survey have a median population
served of 110,500 people and 33,000 accounts. In 2018, 28 percent of respondents indicated that their
stormwater operations were governed as a stand-alone stormwater utility, while 23 percent were
combined with a department of public works and 20 percent each with a water and/or wastewater
utility or other entities.
In the 2016 and 2018 surveys, as well as many previous surveys, respondents cited funding or
availability of capital as the most important challenge to enhancing their utilities' stormwater
management. In 2018, 94 percent of respondents reported that more than 75 percent of their revenue
is derived from user fees. Additionally, survey results showed that the majority (87 percent, on par with
2016 and 2014 responses) of capital improvement projects are cash-financed, as opposed to debt-
financed.
Respondents' 2018 annual stormwater capital improvement program budget ranged from $1,800 to
$143.9 million, with an average of about $7.6 million. According to the 2016 survey, 88 percent of
respondents indicated that they do not have adequate funding to meet all their stormwater programs'
needs, while 85 percent of 2018 respondents indicated that funding was not adequate. This aligns with
survey responses to the same question from the 2010, 2012 and 2014 reports. Neither the 2016 nor the
2018 survey explicitly discussed funding and needs for O&M activities, although 2018 survey
respondents indicated that stormwater utility budgets generally do capture costs for inlet and outfall
maintenance and best management practice inspection and maintenance.
4.3 Clean Wa urv teport to Congress (2016)
The EPA conducted its most recent Clean Watersheds Needs Survey (CWNS) in 2012 and published in
2016. The CWNS estimates the capital investment necessary to meet the nation's stormwater and
wastewater treatment and collection needs, based on Clean Water Act requirements. Water quality
improvement investments considered in the CWNS included stormwater management. This category
captured costs associated with the planning and implementation of structural and non-structural
measures to control runoff in Phase I, Phase II and non-traditional MS4s.
This voluntary survey captures needs across most states, Puerto Rico, the District of Columbia and U.S.
Territories ("states"). While the goal of the survey is to capture 20-year need nationwide, because states
had limited documentation to demonstrate needs over this longer timespan (most projects will be
completed within a 5-year period), most of the needs captured in the 2016 report only reflect 2012 to
2017 needs.
Information provided by the states captured needs for over 27,000 wastewater facilities and water
quality projects. Of the estimated $271 billion required to meet documented needs, an estimated $19.2
16 The following states did not participate in the 2016 and 2018 surveys: AK, AL, AR, AZ, CT, HI, ID, IN, LA, MA, ME,
Ml, MS, ND, NH, NJ, NM, NV, NY, Rl, SD, UT, VT, Wl, WV, and WY. The following additional states did not
participate in the 2018 survey: NE, OK, and MD. In 2018, 33 respondents represented three states, Florida (16),
Texas (10) and Colorado (seven).
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billion was for stormwater-related needs. This represents a 60 percent decrease from the 2008 CWNS,
but this decrease is due in part to lower participation in the 2012 CWNS. Three fewer states participated
in 2012, and seven states reported no needs in 2012, which accounted for $7.2 billion of the 2008
survey's needs. Additionally, EPA's estimate only included projects that had a "storm water quality
benefit" and thus did not include needs associated with flood control projects in the estimates. As a
result, states reported that this modification made it difficult to meet EPA's documentation criteria for
stormwater in 2012. Of the $19.2 billion for stormwater needs, 45 percent is attributed to conveyance
systems, 32 percent for the treatment of stormwater runoff (e.g., ponds, manufactured devices), and
the remaining 15 percent for low-impact development and green infrastructure projects.
Additionally, the CWNS only includes projects with site-specific solutions to known water quality
problems and detailed cost information. Needs associated with water quality problems without known
solutions and cost estimates were not captured.
4.4 Florida Stormwater Association } 6 and 2018)
In 1995, the Florida Stormwater Association (FSA) began performing biennial Stormwater Utilities
Surveys to provide stormwater program information to state and local government managers and policy
makers. The FSA provides questionnaires to the 67 counties and 410 cities in Florida. Of those 477
entities, FSA estimates, 165 local governments have established stormwater utilities. In 2016, 124
utilities responded to the questionnaire; in, 2018 FSA received 137 responses. In 2016, 88 respondents
(71 percent) cited user fees as their primary approach to revenue generation. In 2018, 91 respondents
(66 percent) reported the same. In both surveys, about 70 percent of respondents indicated that fees
were primarily based on impervious area.
Eighty-two entities in 2016 and 89 entities in 2018 reported that their stormwater operating budgets are
funded solely by their stormwater fees. The rest (42 in 2016 and 47 in 2018) indicated their budgets
were covered by fees and other "non-fees" including, but not limited to, ad valorem taxes, sales tax and
gas tax. The 2016 survey indicated that 44 percent of stormwater capital construction programs were
funded only by fees, while the remainder was funded by fees and non-fees. Responses were very similar
in 2018.
In 2016, 66 percent of respondents reported that their operating budgets are funded only through fees.
Of the 34 percent for which fees and other non-fee funds fund their operating budgets, 45 percent
reported ad valorem taxes as the source of non-fee revenues. Responses to these questions were nearly
identical in 2018.
The 2016 report identifies the annual average revenue generated by each entity's utility fee as $3.6
million, whereas the 2018 report lists the annual average as $3.9 million. Respondents reported a
combined projected capital improvement need of $1.7 billion for the next five years and $3.3 billion for
the next 10 years (per-utility average of $14 million and $35.1 million, respectively). This represents an
increase from 2016 reported total respondent needs of $1.4 billion (five-year need) and $3.1 billion (10-
year need). Respondents were also asked whether stormwater fee revenue was sufficient to meet
administration, O&M and capital improvement needs. In 2018, 33 percent of respondents indicated that
fees were sufficient to meet all or most needs, while 26 percent reported that fees were not adequate
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to meet urgent needs. In 2016, responses to the same questions were 39 percent and 37 percent,
respectively. Respondents were not given the option to indicate whether fees were not adequate to
meet non-urgent needs.
4.5 Georgia Stormwater Utilities Report (2017)
From August 2016 to February 2017, the University of North Carolina's Environmental Finance Center
and the Georgia Environmental Finance Authority surveyed 48 stormwater utilities in 27 Georgia
counties regarding stormwater fees. Of the 48 respondents, 23 reported collecting fees through utility
bills, while 20 reported collecting fees through property tax bills and five through stand-alone bills. Of
the participants, 31.2 percent indicated they apply unique multi-family residential fee structures. In
Georgia, flat fee structures are commonly used to apply fees for multi-family and single-family
residential properties. Lastly, 93.8 percent of respondents indicated that they charge an equivalent
residential unit (ERU)-based fee for non-residential properties, which is based on the amount of
impervious surfaces on a property.
The Southeast Stormwater Association conducted its seventh biennial survey of stormwater utilities in
2019, capturing information from 103 respondents representing stormwater utilities from 136
jurisdictions in Georgia, South Carolina, North Carolina, Alabama, Tennessee, Florida and Kentucky.
Ninety-four percent of respondents reported generating revenue from a user fee, largely based on the
amount of impervious area on a property. Annual reported revenue generated by the stormwater utility
fee ranged from $32,000 to $71.1 million, with an average of $4 million. Average monthly utility rates
ranged from $0.62 in Alabama to $5.36 in South Carolina.
Across 67 respondents, the estimated total 20-year capital improvement need is $9.7 billion, with an
average of $144.8 million in need per respondent.
In 2016 the Chesapeake Stormwater Network surveyed Phase I and Phase II MS4 permittees within the
Chesapeake Bay watershed (Virginia, Maryland, Delaware, West Virginia, Pennsylvania, New York and
Washington, D.C.) to identify funding needs. A total of 137 respondents provided input for the survey.
Seventy-three percent of respondents indicated that their stormwater program is somewhat (45
percent) or very (28 percent) underfunded. Respondents also cited resource limitations and scale of
permit requirements as the most significant challenges to permit implementation.
The majority (65 percent) of Phase I permittees responded that they have an approximate annual
budget of over $1 million. The remaining Phase I permittees indicated the following: 8 percent operating
on a budget of less than $25,000, another 8 percent operating on a budget between $25,001 and
$100,000, 5.4 percent operating on a budget between $500,000 and $1 million, and 13 percent unsure
of their operating budget.
4.8 Southeast Stormwater Associm
4.7
SlJfUcf
t Results of the MS4 Needs
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The majority of Phase II permittees (36 percent) indicated that they have less than $25,000 to
implement their programs. The remaining Phase II permittees indicated the following: 21 percent
operating on a budget between $25,000 and $100,000, 8 percent operating on a budget between $500
and $1 million, 7 percent operating on a budget between $100,001 and $500,000, and another 7
percent operating on a budget of more than $1 million, and 18 percent not sure of their budget
allotment.
4.8 Water Environment Federation MS4 Net merit Survey Results
(May 2019)
The Water Environment Federation's (WEF's) Stormwater Institute conducted a national survey of MS4
permittees in 2018 to identify permittees' information and technical resource needs and better
understand the challenges facing MS4 permittees. A total of 622 respondents represented 48 states and
Washington, D.C. The sample size was statistically significant and generally representative of the
distribution of MS4 programs across the United States, including municipal, non-traditional and state
department of transportation permittees. The survey determined the total annual funding gap for
stormwater programs in the MS4 sector to be $8.1 billion nationally.
Phase I and Phase II MS4 respondents cited lack of funding or availability of capital, aging infrastructure,
and increasing or expanding regulations as the most significant challenges to their stormwater
programs. Close to 50 percent of Phase I and II municipal permittees indicated that they do not have
enough money to meet program goals, and that a respective 52 percent and 136 percent annual budget
increase is needed. Respondents also indicated a need for more information on methods for securing
funding and financing. Specifically, respondents indicated needing additional information on "leveraging
additional sources of funding based on co-benefits."
WEF indicates that the number of MS4s with inadequate annual budgets may be underrepresented due
to unwillingness to answer questions that might only raise further questions about their budgeting
process or regulatory compliance.
4.9 i( L. .vater Utility Surveys (2013, 2016, 2018
Western Kentucky University (WKU) has been conducting a regular survey of stormwater utilities since
2007. The WKU team mines publicly available online data on stormwater utilities, in addition to
conducting phone surveys. The survey aims to identify as many stormwater utilities as possible within
the United States and Canada.
The number of identified stormwater utilities has been increasing in each survey. The 2013 survey
identified 1,417 stormwater utilities in the United States, compared to 1,583 in 2016, 1,681 in 2018, and
1,716 in 2019. The 2019 survey reported that 800 of these utilities fund their programs with ERU-based
user fees. These reported monthly fees have generally increased through the years from $4.57 in 2013
to $5.85 in 2019 (median of $4.75), even though the average impervious area based on the ERU has
varied. This is largely attributed to the application of tiered fees and the fee structure that is applied to
residential and non-residential properties.
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As previously stated, the Task Force believes, based on the many existing surveys on stormwater funding
needs, that a significant gap exists, well into the billions of dollars per year and left on the current
course, that gap will continue to grow.
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5.0 Existing Sources of Funding
Identify existing federal, state and local public and private sources of funding for
stormwater infrastructure and how funding for stormwater infrastructure from
such sources has been made available, and utilized, in each state to address
stormwater infrastructure needs.
Stormwater management at the local municipal level has changed significantly within the last 20 years
as discussed in earlier sections of this report. The following are some of the factors that have raised the
average cost of stormwater programs (adjusted for inflation) over what it was 20 years ago:
* The increased use of green stormwater infrastructure for stormwater management
* The maturation of many water quality programs and the increase in infrastructure maintenance
needs
* The impacts of more intense rainfall
* The necessity for resilience planning and implementation of initiatives
* The realization that underground stormwater systems were reaching the end of their functional
lives, requiring massive rehabilitation and replacement programs
This cost increase necessitates an evaluation of existing sources of stormwater funding, as well as ways
to either further leverage existing funding sources or identify potential new sources of funding.
5.1 The Role of the Federal Government in Funding Stormwater Programs
To date, the role of the federal government has been to provide minimal funding for selected capital
projects, often with a significant match required and for targeted and limited programs, with availability
further limited by annual appropriations. For example, for flood resiliency support, federal programs
include Housing and Urban Development Hazard Mitigation Grants, Community Development Block
Grants, FEMA Pre-Disaster Mitigation Programs and Flood Mitigation Assistance, U.S. Army Corps of
Engineers (USACE) flood risk management studies and projects, and U.S. EPA loan programs, etc. Even
though these programs provide small contributions to the construction of capital projects, they do not
provide funding for the bulk of the stormwater needs: compliance requirements, infrastructure
operations and maintenance, and additional capital expenditures. In addition, most USACE flood risk
management funding is for large projects that typically do not address the stormwater needs of small
communities.
Existing funding has proven inadequate for current and anticipated future costs associated with proper
stormwater management. Certainly, it is not expected that the federal government should meet all
funding needs—but it has opportunities to provide leadership and increased funding to allow local
communities to better address stormwater management needs. The needed federal investment in
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stormwater infrastructure is similar to federal funding programs used in the past to begin construction
of our interstate highway system and upgrade wastewater treatment plants.
Ultimately, local communities committed to raising or implementing stormwater user fees or other
dedicated and sustainable funding sources to more realistic levels, in concert with the ability to
repurpose the various existing federal programs, could go a long way in solving existing problems. In
some cases, communities can manage and fund the local stormwater collection and water quality
program. The difficulty is to find funding for communities with:
# Extreme events and large system flooding issues.
i Lack of resources to meet compliance requirements, environmental standards or consent decrees
that go beyond typical water quality issues.
i Operations and maintenance needs for stormwater infrastructure (treatment and collection).
i Vast sections of very old and inadequate stormwater piped drainage systems. In many of these
cases sources of the problem exist outside the boundaries of the community.
5.2 Stormwater Funding—Types and I
In the face of increasing costs, communities across the United States have implemented a wide range of
approaches to fund stormwater programs and related capital projects—but few have the revenue
capacity or one-time influx of funds to support anything beyond small capital projects or ancillary
programs. Stormwater funding tends to fall into three categories:
i Revenue—an ongoing stable and meaningful flow of funds, including taxes of various types,
franchise fees and stormwater user fees, as well as intermittent revenue from various special fees
and charges.
~ Capital financing—targeted capital funding for a specific project, such as state and federal grants,
state and federal loan programs, general obligation or revenue bonds, and other short or long-term
loans.
* Other resources/approaches for funding stormwater management, including development by
others—new development and redevelopment creating stormwater infrastructure or partnership
approaches, other in-kind services or volunteer programs, approaches that can shift risk or delay
payment such as public-private partnerships, market-based solutions, and other innovative
approaches.
The following table (
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Table 1) provides a stormwater funding matrix that further outlines examples of stormwater funding
currently used by communities, along with advantages and disadvantages of each. Most communities
use more than one source of funding. The following sections further explain the sources and uses of
each type of funding.
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Table 1. Funding Type Matrix, including a Description of the Funding Source and Associated Advantages and Disadvantages.
Funding Source
Description
Advantages
Disadvantages
1.0 "Revenue-Based" Funding Sources used to pay on-going Operation & Maintenance and Debt Service of the Stormwater System
l.A Recurring, Sustainable Revenue Sources for On-going Stormwater Program Funding
• Provide regular, recurring revenues to fund both operating and capital related costs
Taxes/ General
Funds
Funds raised through taxes such as
property, income, and sales that are
paid into a general fund.
• Consistent from year-to-year
• Utilizes an existing funding system
• There can be significant competition for funds;
• Tax-exempt properties do not contribute;
• System is not equitable (does not fully reflect
contribution of
stormwater runoff)
Taxes/ Dedicated (e.g.,
local option sales tax,
Gas Tax, drainage or
special assessment
district)
Funds raised through taxes such as
property, income, and sales that are
restricted, in part or in whole, for
funding stormwater costs.
• Consistent from year-to-year but can vary
(e.g., changes in property values or rise and
fall with economic cycles)
• Utilizes an existing funding system
• Can be targeted for a specific purpose (e.g.
ongoing maintenance, capital, etc.)
• May be competition for funds if not exclusively
restricted to stormwater;
• May require approval by vote of the local legislative
body and public if a new tax
• Often have a "sunset" clause resulting in stable
funding only for a specified period of time (e.g., 10
years)
• Tax-exempt properties do not contribute;
System is not equitable (does not fully reflect
contribution of stormwater runoff)
Stormwater Utility User
Fee (Enterprise Fund)
A stormwater utility generates its
revenue through user fees and the
revenues from the stormwater
charges will go into a separate fund
(e.g. enterprise fund) that can be
used only for stormwater services.
• Dedicated funding source
• Directly related to stormwater impacts
• Sustainable, stable revenue
• Shared cost
• Equitable apportionment of costs
• Improved watershed stewardship
• Addresses existing stormwater issues
• All properties served pay fee
• Feasibility study required for implementation, fee
structure, and administration of utility
• Requires approval by vote of the local
legislative body, in some cases public vote
required
• Perception by the public of a "tax on rain"
• Public acceptance for a first-time fee is difficult
• Some states have not yet allowed SW Utilities
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This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or approved by the chartered EFAB, and does
not represent EPA policy.
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Funding Source
Description
Advantages
Disadvantages
l.B Intermittent Revenue
• To recover a portion of costs related to which fee is assessed
Fees
Revenue raised through charges for
services such as inspections and
permits.
Revenue raised through developer
related fees are one-time charges
linked with new development.
• Specific permit and inspection fees allow for
more direct allocation of costs for services
provided
• Fees can be set to fully recover cost
• Certain kinds of fees can provide funding for
long-term maintenance
• Addresses potential stormwater impacts
related to new construction
• Not available for larger projects or system-wide
improvements
• Developer impact fees may be an unreliable source
when development slows (due to market
downturns/contractions)
* Requires administrative framework to assess and
manage
* Legal limitations may constrict or restrict usage
Special Charges (e.g.,
impact fees, latecomer
fees, system
development charges,
special assessments,
surcharges on other
utilities)
A number of different fees that
attempt to shift certain program
costs to provide a better cost
causation match. Payees might be
other local programs, development
interests, other local government
programs, or parties requiring a
myriad of special services or
penalties.
• Improves cost causation equity match
» Allows special services to be paid for by
recipients
• Provides additional funding in a manner
acceptable to the general public
• Recovers the cost of negative impacts of
other activities on the stormwater system
• Level of funding is unpredictable and can vary
significantly year to year
• Can be hard to administer
• May be seen as discouraging development or
other desirable activities
• May be difficult to price accurately
• While some sources may fund certain O&M
(e.g., staff time), others, such as impact fees
and SDCs are generally restricted to capital
funding only
l.C Capital Financing Sources (Financing Vehicles, require repayment)
• Borrowing for capital projects
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Funding Source
Description
Advantages
Disadvantages
Bonds (Debt
Obligations)
Bonds are not a true revenue
source, but are a means of
borrowing money to finance capital
projects. Bonds are generally issued
with a term less than the expected
useful life of the assets financed.
Bonds may be general obligation
(GO) bonds backed by taxes, or
revenue bonds, backed by a secure
revenue source (most commonly a
stormwater user fee). "Green"
bonds are a designation of bonds
dedicated to environmentally
friendly projects, including clean
water projects.
• Existing sources available for
stormwater-related funding
• Can support construction-ready projects
• Allows a community to complete large
projects sooner than revenue cashflows
become available, or a significant
stormwater capital program more quickly
• Spreads the cost of the capital project over
time, allowing beneficiaries of the
improvements to pay over the life of the
bonds, rather than current property owners
paying up front.
• Mitigates the risk of construction cost
escalation
• Accelerates ability to address important
health and environmental issues
• May require approval for each issuance, in
some cases, voter approval
• Requires access to funding for full repayment of
principal borrowed
• Interest costs can vary but will add to total project
cost
• Requires dedicated repayment revenue stream
• May require design-level documents to be
prepared in advance of debt funding
• Cannot be used to fund O&M if they are tax
exempt bonds.
• Will require additional funding for costs of
issuance
• May require significant administrative preparation
to issue and for post compliance activities and
disclosures.
Loans (Debt Obligation)
Low-interest loans, for example the
SRF loans, may be secured, and are
generally used for planning and
capital
projects.
• Existing sources available for
stormwater-related funding
• Offers low- or no-interest financing
• Loan interest loan programs may offer ease of
issuance relative to public offerings
• One-time source of funds
• Requires full repayment of principal borrowed
• Administrative requirements can be time-
consuming
• Loan interest loan programs may come with
inflexible mandates and restrictions
l.D One-time Sources
• Generally used for capital projects
Grants
State, federal, local and non-profit
grants provide additional funding for
water quality improvements.
• Existing sources available for
stormwater-related funding
• Does not require repayment
• Competitive
• Typically, one-time, project- specific, or time-
constrained funds
• Often requires a funding match
• Does not fund post-project O&M
• Matching grant requirements and project needs
difficult
2.0 Other Resources/Approaches for Funding Stormwater Management
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Funding Source
Description
Advantages
Disadvantages
Public-Private
Partnerships (P3)/
Alternative
Service Delivery
(ASD)
Contractual agreement between a
public agency and a private sector-
generally used for capital projects.
Partnering with private enterprise
can expand access to resources and
capital and offer better economies
of scale. P3/ASD shifts both risks
and duties from the traditional
procurement and project
management context Examples
include: Design/Build,
Design/Build/Operate/Maintain/Fin
ance, Pay-for-Performance (also
sometimes referred to as Pay-for-
Success), etc. May include private
financing, or a combination of public
and private financing.
• May be structured to require minimal to no
initial cash outlay for public sector, assuming
the private sector partner is providing
financing
• Efficiency through bypassing bureaucracy or
economies of scale
• Flexibility & creativity of project approach,
new technology adoption and
contracting/procurement
• Access to flexible & creative private sector
financing
' Significantly leverages public resources
' Draws on private sector expertise
• Enables transfer of compliance from one
development to another
• Partnerships can be with not-for-profit
entities
• Considers a project's full lifecycle, potentially
including O&M
• Risk is shared with or passed entirely to
private entity
• A local revenue source is needed to fund the
partnership
• May be structured so as not to require new
funding; may rely on underlying public revenue
stream (e.g. user fees, taxes, etc.)
• May require enabling legislation
• Substantial education and socialization is required
to manage public perceptions related to loss of
control and escalated costs
• Initial financing costs inherent within P3/ASD may
be higher than municipal debt.
• A lack of public agency experience may
necessitate the need for additional resources to
complete a successful contract negotiation
Private
Development
Sites
Private sites build distributed 1 » When well-regulated and inspected these
stormwater infrastructure (e.g. Low i structures and systems are the first, and most
Impact Development, BMP's, i important line of defense against flooding,
conveyance, etc.) that contributes to | erosion and pollution
the overall municipal goals OR j • Inspection and enforcement costs are
contribute funding in lieu of comparably low but with significant return on
construction. Usually required by investment
local ordinance or conditions of j # Capital expenditure and permitting costs are
approval OR set up as a development; borne by private development
impact fee. The proper construction : , often required by regional NPDES permits and
and ongoing maintenance of these enforced by municipa|ities
sites constitutes a major stormwater ;
expenditure of significant
importance. |
• Political will, budget, and legal capability to enforce
long-term maintenance, and sometimes initial
construction standards may be lacking
• Funding is only triggered when regulated
development occurs, which can be hard to plan
around and predict - particularly in a low
investment environment or with regulations that do
not capture the majority of development and
redevelopment activities
• Development may not happen in areas of greatest
need in watershed/community
• Additional education of Public knowledge may be
required
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This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or approved by the chartered EFAB, and does
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Funding Source
Description
Advantages
Disadvantages
• Impact of such programs is hard to measure unless a
high percentage of the watershed has been
constructed with modern requirements
• Distributed infrastructure may not be efficient in
treating and managing SW flows
' Ensuring O&M is difficult and requires municipal
resources
• Development impact fees requires robust needs
analysis and nexus findings (could also be an
advantage)
Volunteer
Programs
In-kind initiatives that can help
support stormwater priorities
• No cost to stormwater program
• Can help increase public awareness
• Some not-for-profits come trained and ready
to work
• Can bolster public support for a user fee
• Limited impact from overall revenue perspective
• Requires coordination, training and supervision
Coordination with
other Municipal
Departments and
State Agencies
Synergize with other city | * Eliminate duplication of effort
departments, agencies, etc. to j « Move toward a "water agency" that can
leverage available community funds j integrate water as a single resource
for stormwater needs ; Allows easier/quicker response for
emergencies
j - Multiple funding or resources may be
[ harmonized; the "whole being greater the
| sum of the parts"
• Transportation projects can add SW elements
for marginal costs (sometimes)
• State DOTs right of way limitations often
compel them to partner with municipalities to
achieve SW goals
• Stormwater may be seen as a secondary priority
behind water and wastewater or public works focus
on roads
• Can lose ability to react to stormwater needs if
equipment and manpower is not dedicated
• May require additional education of personnel or
additional resources with stormwater expertise to
make stormwater decisions
• Disparate-agency partnerships can be difficult to
manage
• Mixing funding sources (particularly with grants) can
be challenging
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This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or approved by the chartered EFAB, and does
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Funding Source
Description
Advantages
Disadvantages
Market-Based
Solutions
The off-site provision of required
stormwater controls on another site,
or in another way, that is seen as
more cost effective to a property
owner or developer, but equally
effective in attainment of the
regulatory standard.
• Creates cost efficiencies in placement of
stormwater controls
• Can allow for aggregation for better overall
control and treatment
• Can shift and target controls to more critical
locations
• Can be complex to administer
• Requires clear and enforceable policies on
ownership and maintenance
• Markets may be not be initially viable and may need
to be jumpstarted with local funding
Newer Innovative
Approaches
A wide variety of approaches that
seek to exploit unique or unusual
funding sources: sponsorship of
stormwater or green infrastructure
sites, adopt-a-road advertising, tax
increment funding, use of private
land for public infrastructure, shared
right-of-way, seed money and
expertise, leveraging user fee
credits, philanthropy, etc.
• Can provide funds at little cost
« Can motivate the private sector through name
recognition
' Can provide good return on seed money
investment when paired with private actions
» Can be hard to administer and explain
* May require opinions and analysis on legality
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*37*
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5,2,1 Revenue-Based Funding Sources Used to Pay Ongoing Operation and
Maintenance and Debt Service of the Stormwater System
The majority of ongoing stormwater program costs must be funded with revenue from dedicated
recurring sources, making revenue-based funding the "backbone" of stormwater funding. Revenue-
based funding tends to fall into two broad categories: recurring, sustainable revenue sources and
intermittent funding.
5.2. J. I Recurring, Sustainable Revenue Sour
Almost all activities undertaken in a stormwater program are ongoing (excluding capital costs such as
construction) and therefore must have ongoing, stable, dependable sources of revenue. Activities that
require recurring, sustainable revenue include ongoing services to plan, rehabilitate and maintain the
stormwater system, conduct programs to meet regulatory requirements, and accomplish a variety of
ancillary responsibilities related to stormwater management.
5.2.1.1.1 Taxes/General Funds
Taxes (of several types) are by far the largest source of revenue for local governments. Such taxes,
unless dedicated, are placed into a local government's "general fund." While the types of taxes
assessed, and the proportion of revenue generated from each, vary from state to state, the bulk of local
government revenue most commonly comes from property tax and income tax assessments. This is true
even though communities are increasingly looking to other revenue sources such as stormwater utility
user fees.
§ Real estate/ property taxes, also called ad valorem taxes, are charged to property owners as a
percentage of the assessed value of real estate or personal property. They are administered by local
governments and require voter approval. Property taxes are an important form of revenue for local
governments; they are often used as a funding mechanism for parks and open space measures.
i Individual income taxes, also called personal income taxes, are assessed at the state and federal
levels (and, in some places, also at the county or municipal levels).
§ Specialized taxes can also be levied on a large number of parameters, including property transfer,
occupancy, gambling, estate, motor vehicle sales and licensing, etc.
The primary advantage of using general fund taxes to fund stormwater programs is that they can
provide a reliable (but fluctuating) revenue stream. They are also common and well understood.
However, there is significant competition for such funds, with most communities finding it difficult to
cover all general fund activities (e.g., police, fire, streets, general government) with available funding. As
a result, communities often find that stormwater programs are prioritized lower than other municipal
needs, and thus risk losing funding from year to year unless there is a dedicated source of funding for
the stormwater program. Another disadvantage is that the use of general fund tax revenue as a
stormwater funding source raises equity issues, as system revenue recovery generally bears no relation
to use of, or benefit from, a stormwater system. This causes an inequity between the level of service
provided and the cost property owners incur. In addition, tax-exempt properties do not pay general
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fund taxes, causing further inequity as the costs they incur must be recovered with revenue from other
properties.
5.2.1.1.2 Taxes/Dedicated
Beyond general fund taxes, many communities use dedicated taxes to fund stormwater program costs.
These may take the form of dedicated sales taxes, motor fuel taxes or special assessments.
# Local sales taxes are often add-ons to state general sales and use taxes. They may also exist where
there is no state sales tax. Depending on state constitutions, statutes and home rule traditions, most
local governments must seek voter approval to levy local sales taxes. State authorization processes
vary. States may give approval to all counties or communities or limit authorization to specific
localities. Local taxes are usually limited to a specified time period (i.e., a sunset provision) or a
dollar collection total, and are generally dedicated to a specific use. The dedicated revenue stream
may be used for operations and maintenance costs, to back local general obligation or revenue
bonds, or to pay for a specific stormwater program directly.
A Motor fuel taxes are imposed at the state and federal levels and are levied on gasoline and other
fuels. All 50 U.S. states and the District of Columbia assess gasoline taxes. State gasoline tax rates
generally range from 14.65 cents to 58.7 cents per gallon.17 State and federal motor fuel tax
revenues are typically dedicated to highway construction and maintenance. Revenues from state
and federal motor fuel taxes could be earmarked to fund stormwater infrastructure related to
roadways, though competition for such funds is fierce—roadway resurfacing and repair are normally
the top priority.
* Special assessments or special taxing districts or service/ drainage districts are recurring
surcharges levied by local jurisdictions on subgroups of the population or even the entire
population, in the case of districts that cover the entire community. Some localities levy them in the
form of taxes dedicated to stormwater management; others levy them as fees. The group paying the
recurring charges receives benefits from a stormwater service or improvement not enjoyed by
others in the area. For example, if a community wants to finance regional stormwater
improvements, residents within the protected area or the contributing area could be charged a
special assessment. Special assessments are generally charged by local governments and authorized
by local ordinance. They are often barred by legislation from use by some states. Special
assessments are used to fund water works systems, sanitary sewer systems, installation or repair of
water and sewer service lines, flood protection projects, and other purposes.
5.2.1.1.3 Storrrm Jser Fees
Stormwater management resembles drinking water and wastewater utilities far more closely than
municipal responsibilities such as police, schools and roadway maintenance, in that the cost recovery for
utility services that are provided can be closely aligned with the service demands of the users.
17 As of 2018; excludes the federal excise tax of 18.4 cents per gallon (httpsi//taxfoundation,org/state-gas-tax-
rates-iuly-2018/).
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This has led to the concept of a stormwater utility user fee. A stormwater user fee is similar to a
wastewater user fee in that it is developed to recover the costs of the stormwater program based on
each property's estimated use of the stormwater system. The first user stormwater fee systems
appeared in the United States in the mid-1970s, and their apparent success in generating significant,
sustainable revenue while keeping the typical homeowner's fee below a critical reactionary level led to
many other communities to follow suit. Local water quality and flood control agencies/districts or
utilities are typically responsible for designing, assessing and collecting user fees (or taxes, as noted
above) based on a property's contribution to the stormwater management system. Today there are
about 1,760 stormwater enterprise funds (stormwater utilities) employing user fees to fund their
programs and to fund revenue bonds for capital construction.
A stormwater user fee falls into the municipal revenue generation mechanism called a "service charge."
Service charges are not established
simply to generate general fund
revenue, but must be tied to the
objectives of a specific program to
which they are associated. A
stormwater utility generates its
revenue through user fees, and the
revenues generated from the
stormwater user fees is placed in a separate fund—called an enterprise fund—that can normally be used
only for stormwater services. Stormwater user charges are designed to provide a nexus between the
user fee and the service provided. As such they differ from taxes.
The amount each rate payer is charged must be related to the "use" of the system (rational nexus),
which can be interpreted as either direct use through runoff contributions or use through protection
from flooding of the property and streets by local stormwater program efforts. When a forested or
grassy area is paved, a greater flow of water (runoff) is placed on the drainage system. This is the
demand. The greater the demand (i.e., the more the parcel of land is paved or otherwise covered with
an impervious surface), the greater the user fee should be.
While there are similarities between a stormwater utility and water/wastewater utilities, a stormwater
utility differs from drinking water and wastewater utilities in several key ways:
§ There is no way to remove or discontinue services for non-payment, as long as the physical property
exists.
A The stormwater management service is provided within the entire jurisdiction regardless of whether
one or more property deems it necessary or not. This is because stormwater management is
performed as a community-wide level of service and not distinctly as an individual property level
service (though mandatory water and wastewater service makes this difference less of a distinction).
§ The demand placed on the system can only be roughly measured or approximated, as it is not
possible to directly measure stormwater flow.
Storrr user fees „, greatest
oppom ' ' ie comr bs with
' linouit i reveni id
A/ate,
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i The actual service rendered to a particular property is often difficult to quantify without the use of a
reasonable and consistent approximation approach.
Despite these differences, the utility concept can be a viable and flexible revenue generation approach
to stormwater funding. According to the 2019 version of an annual survey by Western Kentucky
University, at least 1,716 stormwater utilities currently exist across 40 states and the District of
Columbia, serving a total population of nearly 115 million (35 percent of the U.S. population).18 The
authority (enabling legislation) to implement such an approach varies from state to state, and even from
municipality to municipality, depending on the details of state-granted authority or home rule
requirements. Of the 10 states that do not have utilities, three are either conducting feasibility studies
or exploring changes in state law to allow implementation of stormwater utilities.19
Even in utilities that have a dedicated user fee, which can be used to support debt service associated
with capital program financing, while a Black and Veatch 2018 biennial survey reports that most
responding stormwater utilities (87 percent) use cash financing instead of long-term debt financing for
funding their capital program investments.20 This indicates that stormwater utilities seldom use the
capital markets to augment their financial capacity, which can delay needed upgrades and/or affect the
pace of compliance programs. Further, only 15 percent of respondents indicated that utility revenue is
adequate to meet all needs. The median annual revenue per capita reported in Black and Veatch's
survey was $54, with the maximum annual per capita revenue reported being $200. WKU does not
provide annual revenue details for all utilities surveyed, but found roughly $2.2 billion in utility fees,
with 20 percent of that figure coming from one utility: Chattanooga, Tennessee. More research is
needed to provide a full accounting of all public revenue that is raised toward stormwater management
and compliance.
State statutes may prevent the creation of a stormwater user fee without a ballot measure or enabling
state legislation. This is discussed in detail later in the report.
5.2.1. lititfiiiiii
While it is imperative that communities have in place one or more recurring, sustainable funding
sources, there are other types of funding that while more intermittent, can provide some additional
benefit and help recover certain costs of stormwater management.
5,2,1,2,1 Spe
A growing common practice is the use of fees and specific charges to help fund services by local and
state government. Special fees tend to focus on specific beneficial government services, while charges
18 Campbell, C. W. 2019. Western Kentucky University Stormwater Utility Survey 2019.
httpsi//digitalcommons, wku.edu/seas faculty pubs/1
19 Campbell, C. W. 2019. Western Kentucky University Stormwater Utility Survey 2019.
https://digitalcommons.wku.edu/seas faculty pubs/1
20 Black & Veatch. 2018. "Stormwater Rate Structure and Billing." In 2018 Stormwater Utility Survey.
httpsi//www.bv.com/sites/default/files/2019-
10/18%2QStormwater%20Utility%2QSurvey%20Report%20WEB O.pdf
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m m #
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are defined more broadly in terms of receiving special benefit or service. "When certain services
provided especially benefit a particular group, then governments charge fees on the direct recipients of
those that receive benefits from such services." Often the size or level of the fee is derived from the
actual cost of such provision. "However, many governments provide subsidies to various users for policy
reasons, including the ability of residents or businesses to pay. Well-designed charges and fees not only
reduce the need for additional revenue sources but promote service efficiency."21
Special fees tend to fall into several categories:
# Fees for development-related services such as plan review, inspection, environmental permit fees,
septic system inspections and other similar types of services.
i Fees to defray the cost of specific government services such as specialized disposal (e.g., oil),
recycling, tolls, certification, bond issuance, licenses, etc.
§ Fees for government services or land, such as franchise fees, or indirect cost allocations from other
enterprise funds for general governmental purposes.
Such fees focus costs on recipients of special services and not the general public, and they address
potential stormwater impacts during the critical construction phase. On the other hand, it is often
difficult to set such fees at a level that recovers the full cost of the activity necessitating the fee. In
addition, revenues from such fees are intermittent and, thus, when that activity is not occurring no
funds are received even though local government costs (such as personnel) may be stable and ongoing.
5.2,1,2,2 Spe-;
Special charges are often not distinguished from fees in that they tend to be related to specific
government services or benefits. They do tend to be more complex or related to higher government
functions. Examples include connection fees, impact fees, special assessment or improvement districts,
tax increment funding, developer extension fees, in-lieu fees, latecomer charges, and other exactions.
Conr ?es
Connection fees, also called hookup fees, are typically charged to property owners when they connect
with existing municipal drinking water and wastewater treatment facilities. But they could be used for
stormwater as well. Connection fees are generally levied by local governments or county governments.
Impact Fee..
Impact fees are often assessed on the construction of new buildings. Local governments and county
governments levy impact fees. The revenues are used to pay for improvements to services and
amenities for the occupants of new development (including expansions of police and fire stations,
wastewater and water supply systems, parks, libraries, and schools) and the building of new roads. In
addition, impact fees are often assessed based on the projected environmental impacts of a
construction project, with their revenues used to mitigate those impacts. The drawback of impact fees is
21 Government Finance Officers Association. 2018. "Establishing Government Charges and Fees."
httpsi//www,gfoa,org/establishing~government~charges~and~fees
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that they can only be used to improve an adequate stormwater system in the face of increased demand,
and many systems cannot be shown to be adequate. As well, they typically have sunset provisions.
Exactions
Exactions, also called proffers, are conditions or financial
obligations imposed on developers to aid local governments
in providing public services needed to support new
developments. They are administered by local governments.
Exactions can take a number of different forms. They can
include financing of existing infrastructure facilities or
infrastructure improvements; donations of in-kind services;
and donations of land, water and wastewater lines, and road
and parking facilities. Exactions can also take the form of
impact fees paid in lieu of the types of donations described
above. Exactions allow more flexibility than strict impact
fees because they are not required to be financial
contributions. They may be offered voluntarily by
developers; local governments often negotiate them with
each developer. Most localities use exactions in some form.
Some localities assign building permits competitively based
on the level of exactions offered by different developers.
Special Assessments
Special assessments are recurring surcharges levied by local
jurisdictions on subgroups of the population. Some localities
levy them in the form of taxes; others levy them in the form
of fees. The sub-group paying the recurring charges receives
benefits from a stormwater service or improvement not
enjoyed by others in the area. For example, if a community
wants to finance stormwater quality improvements that
contribute to lake cleanup, residents with waterfront
property could be charged a special assessment. Special
assessments are generally charged by local governments and
authorized by local ordinance. Special assessments are used
to fund water works systems, wastewater systems,
installation or repair of water and wastewater service lines,
stormwater and flood protection projects, and other
purposes, and are sometimes used in conjunction with a
neighborhood development to fund the construction and
ongoing maintenance of a stormwater detention pond or water quality feature.
Case Study: Five San
Francisco Bay Area
Voter-Approved Fee
Measures
Five small- to mid-sized
municipalities in the San
Francisco Bay Area put
new stormwater fee
structures out for voter
approval in 2018 and 2019
(with mixed results). Each
municipality followed a
similar approach including
developing a
comprehensive needs
study or master plan,
conducting a scientific
survey of the community's
priorities and willingness-to-
pay, and executing a
community outreach and
education process aimed
at increasing awareness
regarding local flooding;
storm drainage
infrastructure operations,
maintenance and capital
improvements; and water
quality.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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Special Assessment or Improvement Districts
Another form of local fee comes from the creation of a special assessment or improvement district. In
this case, a district is designated to need stormwater management upgrades—typically green
infrastructure or low-impact development—as part of a broader economic development strategy. The
district then creates a special tax assessment that is paid for by the property owners within the district's
geographic boundary. State and local laws differ on how these districts are created and voted into
existence, what funds are acceptable to be assessed, and how often assessments can be billed. These
assessments may be a one-time or ongoing assessment depending on their purpose. One-time
assessments tend to be raised for capital construction simultaneous to a broader economic
development process. Ongoing assessments may pay for capital construction, administration of the
entity in charge of governing the district, and operations and maintenance of district-owned projects.
Most special assessment districts are subject to periodic renewal based on a vote by their members;
some are mandated by state law to have a sunset clause (e.g., five, 10, 20 years).
Following are some of the advantages and disadvantages of Special Assessment or Improvement
Districts:
i Advantages:
o Improve cost causation equity match,
o Allow special services to be paid for by recipients.
o Provide additional funding in a manner acceptable to the general public,
o Recover the cost of negative impacts of other activities on the stormwater system,
i Disadvantages:
o Funds flow is not generally predictable and steady.
Can be hard to administer.
May be seen as discouraging development or other desirable activities.
May be difficult to price accurately.
Typically, cover staff time only—not funding for operation and maintenance or capital
improvements.
o Typically, cannot be used as leverage for raising debt capital.
5,2,2 One-Time es for Financing of Capital Projects and/or Other
One-Time Initiati
The use of one or more recurring funding sources such as user fees and charges are necessary for any
sustainable stormwater program. However, there are other types of funding sources including debt
financing, grants, and other sources that are available to communities, more and are more conducive to
funding of capital projects and/or help fund special capital program initiatives.
Repository of Funding Sources: The Task Force worked with the EPA to assist in developing a database
of existing funding sources. Sources of funding at the federal, state and local levels as well as private
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
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approved by the chartered EFAB, and does not represent EPA policy.
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funding were compiled, to the extent possible. The results of the effort are found in Appendix III. While
the database should not be construed to be comprehensive, it is an extensive database and the Task
Force feels it is mostly complete as it relates to federal funding sources. The sources identified at the
state, local and private level should be considered representative of the types of funding that may be
available. This database includes multiple Federal grant programs that may be available to stormwater
programs, through EPA, the US Department of Housing and Urban Development (HUD), US Department
of Agriculture (USDA) Rural Utility Service (RUS), and other agencies.
This funding sources database may be available to communities that are interested in examining
potential sources of funding primarily for their stormwater capital programs.
5.2.2.1 Capital Financing Sources (Fin ?qu/re Repaymentj
Debt financing, with either short-term or long-term amortization, is an important capital financing
instrument that is available for stormwater capital program just as it is for the drinking water and
wastewater sectors.
Use of these debt financing instruments for capital
program funding requires dedicated, recurring, and
sustainable revenue source(s) for the repayment of
principal and interest associated with the debt
financing. Therefore, it is important to recognize
that the capital program debt financing funding
source is not just an [alternative] for recurring
sources of revenue but rather a valuable complement for funding capital infrastructure investments.
Debt financing mechanisms can greatly help enhance a community's ability to complete large capital
projects that would not otherwise be possible with just limited cash resources (whether generated
through user fees, taxes, or other sources), and enable a community to plan and execute a larger capital
program. Long-term financing of capital projects provides the additional benefit of spreading the costs
of projects over the life of the asset, with the principal and interest paid by those who benefit from the
project.
Following are the primary types of capital financing available to communities for stormwater capital
program management.
5.2,2,1,1 Bon
"Municipal bonds are debt securities issued by states, cities, counties and other governmental entities
to fund day-to-day obligations and to finance capital projects" including stormwater projects.
"Generally, the interest on municipal bonds is exempt from federal income tax. The interest may also be
exempt from state and local taxes" in some states. General obligation bonds and revenue bonds are the
most common types of municipal bonds. "General obligation bonds are issued by states, cities or
counties and not secured by any assets. Instead, [they] are backed by the 'full faith and credit' of the
issuer, which has the power to tax residents to pay bondholders. Revenue bonds are not backed by
government's taxing power but by revenues from a specific project or source," which could include a
trig 11 icli 11 is can
enhance a
s ability to complete
icts that would
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stormwater enterprise fee. "Some revenue bonds are 'non-
recourse/ meaning that if the revenue stream dries up, the
bondholders do not have a claim on the underlying revenue
source."22 "A 'double barreled' bond is a municipal bond in
which the interest and principal payments are pledged by two
distinct entities—revenue from a defined project and the
issuer and its taxing power."23
An advantage of bonding is that projects can be constructed
earlier and more rapidly; as well, the payment for the capital
project better matches the life of the project, with newer
residents participating in the payment according to their
longevity within the municipality. Disadvantages include the
potential to build up a large debt balance (limiting investment
to meet other stormwater needs), the technical and legal
requirements to obtain bonds, the limitations on bond
capacity within a local government, the potential need for
voter approval, and often the limitations on the use of the
funds to capital construction but not the full suite of life-cycle
costs.
There are many variations on the two general types of
bonding, including anticipation note s, asset-backed securities,
moral obligation bonds, special assessment bonds, and tax
increment bonds.
5.2.2.1.2 Loans
There are a few Federal, State, and private loan type funding
mechanisms —many of them originally targeted toward water
and wastewater programs— that can be leveraged for local
stormwater programs. Relative to borrowing in the bond
market, Loans can often provide a lower cost debt financing as
under special circumstances, Loans can be structured to
include features such as zero interest, very low interest, or
even in some cases principal forgiveness. Some of the loan
programs are targeted at "green" objectives and programs.
In this section, an overview of the following types of loan programs are discussed.
* Clean Water State Revolving Fund (CWSRF) and Drinking Water State Revolving Fund (DWSRF)
22 U.S. Securities and Exchange Commission, n.d. "Municipal Bonds." https://www.investor.gov/introduction-
investing/basics/investment-products/municipal-bonds
23 Chen, J. 2019. "Municipal Bond." Investopedia. https://www.investopedia.eom/terms/m/municipalbond.asp
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
Green Bonds
"A green bond is a bond
whose proceeds are used to
fund environment-friendly
projects...Green bonds
provide investors with a way to
earn tax-exempt income with
the benefit of personal
satisfaction, knowing that the
proceeds of their investment
are being used in a
responsible, positive manner.
The issuers of green bonds also
benefit, since the green angle
can help attract a new subset
of investors, namely younger
investors, whom the issuers can
profit from over an extended
period vs. a base of older
investors...The first entity to
issue green bonds was the
World Bank, which began the
practice in 2008 and has since
issued over $3.5 billion in debt
designated for issues related
to climate change. Ginnie
Mae and Fannie Mae have
also issued mortgage-backed
securities with the 'green'
label, as has the European
Investment Bank."
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i USDA Water and Waste Disposal Loan and Grant Program
§ Water Infrastructure Finance and Investment Act (WIFIA) Loan Program
i State Based Loan Programs
i Private Investments
CWSRF: One of the most commonly used loan programs in the wastewater sector is the CWSRF
loan. Under Title VI of the 1987 Clean Water Act, states receive federal monies to capitalize CWSRF
loan programs. Through CWSRF programs, loans are made to communities to provide low-cost
financing for a wide range of different projects
to protect water quality. Examples of activities and Puerto R'lCO
funded with these loans include nonpoint-
source pollution control, watershed protection ' ]fOms.
and restoration, estuary management, wetlands
restoration, brownfields remediation, and improvements to municipal wastewater treatment
infrastructure. Loans are made at low interest rates (0 percent to market rate) for terms of up to 20
years. In addition, states use CWSRF money to repurchase debt to get these loans to 30 years. States
may set the criteria for determining which municipalities can access the loans each year. All 50 U.S.
states and Puerto Rico operate CWSRF programs. Some CWSRF and Drinking Water State Revolving
Fund (DWSRF) loan programs make short-term loans for planning, design and initial construction in
localities that may later receive long-term CWSRF and DWSRF loans. In addition, state revolving fund
loans may be used to pre-finance other federal or state drinking water loans or grants.24
USDA Water and Waste Disposal Loan and Grant Program: This program "provides funding for
clean and reliable drinking water systems, sanitary sewage disposal, sanitary solid waste disposal,
and storm water drainage to households and businesses in eligible rural areas...Funds may be used
to finance the acquisition, construction or improvement of: drinking water sourcing, treatment,
storage and distribution; sewer collection, transmission, treatment and disposal; solid waste
collection, disposal and closure; and stormwater collection, transmission and disposal."25
WIFIA: WIFIA is the latest federal loan program administered by EPA for eligible water, sewer, and
stormwater infrastructure projects. The program funds development phase activities,
construction/reconstruction/rehabilitation/replacement, acquisition of real property or interest in
real property, environmental mitigation, construction contingencies, and equipment acquisition;
capitalized interest necessary to meet market requirements, reasonably required reserve funds,
capital issuance expenses, and other carrying costs during construction. Applicants must submit a
letter of interest, and based upon several criteria, EPA invites qualified projects to apply for the
WIFIA loan.
24 U.S. EPA. 2019. "Learn About the Clean Water State Revolving Fund (CWSRF)."
https://www.epa.gov/cwsrf/learn-about-clean-water-state-revolving-fund-cwsrf
25 U.S. Department of Agriculture, n.d. "Water & Waste Disposal Loan & Grant Program."
https://www.rd.usda.gov/programs-services/water-waste-disposal-loan-grant-program
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i State Based Loan Programs: There are also many state-based loan programs with a variety of
objectives and requirements. For example, the Georgia Fund Loan Program currently "supports
water, wastewater, and solid waste infrastructure improvements...[with] loans available at a low-
interest rate for a maximum of 20 years."26
i Private Investments: Private investment can take the form of loans and/or other financial assistance
originating from sources other than commercial banks and/or finance companies. Sources of private
investment can include, but are not limited to, insurance companies, pension funds, venture capital
funds, individual venture capitalists, corporation partners and general capital investors. Private
investment funds billions of dollars' worth of new business start-ups in the United States each year.
The potential uses of private investment for supporting environmentally related businesses and/or
activities are only limited by the degree of profit associated with them: if it can be shown that an
idea or activity will make money, then private investment can be found to support it. Applying for
private investment is typically much faster than for government loan programs. Private investors
usually have no set eligibility criteria and may have no predetermined limits on the total amount of
loan capital available. Private investors tend to demand a significantly higher rate of return on their
money, though, than other sources of capital. Note that a private investment can develop into a
public-private partnership of an operational component is added to the mix.
5.2,2,1,3 Grant Type Fundin
A variety of one-time grants are available for supporting specific initiatives of capital projects from
government and private foundation sources. The advantage of such grants is that there is no repayment
requirement and the amounts can be substantial. The disadvantages include the competitive nature of
the grants, the requirement for pre-positioned matching in-kind or funds for some grants, the
limitations on the use of some grant funds, the effort required to file the applications, and the need to
harmonize the grant requirements with the needs of the local government.
There are several federal and state grant programs, including both ongoing programs and one-time
opportunities. Several websites provide a good source for learning about federal grants: sites for
agencies that participate in the water world will present many opportunities, as will http://grants.gov
For example, the 1987 amendments to the Clean Water Act established the Section 319 Nonpoint
Source Management Program. Under Section 319, states, territories and tribes receive grant money that
supports a wide variety of activities including technical assistance, financial assistance, education,
training, technology transfer, demonstration projects and monitoring to assess the success of specific
nonpoint-source implementation projects. Grantees must use these funds to implement U.S. EPA-
approved nonpoint-source pollution management programs. A 40 percent nonfederal match, in the
form of supplies, equipment, and/or funding, must be provided by grantees. Regulatory and
26 GeorgiaGov. n.d. "Environmental Loans & Tax Credits." https://georgia,gov/popular-topic/environmental-loans-
tax-credits
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nonregulatory programs assessing the success of specific nonpoint-source pollution control projects may
be eligible for these grants. Grant totals for the last few years were in the $170 million range.27
Many types of foundations and charitable organizations have begun supporting various aspects of
stormwater-related needs through grant-making. Foundation and corporate grants are a significant and
growing source of funding for environmental protection projects. Most grants of this type fund well-
defined projects, with specified time frames, costs and deliverables that meet the immediate priorities
of the funding source and are not funded by governments. Foundation and corporate grant programs
tend to favor the most innovative environmental projects. Funding such things as green infrastructure
strictly through grants generally is not a sustainable financing strategy, but it may be a way to fund some
high-profile demonstration projects that will attract subsequent sustainable government or property-
owner financial support.
5.2,2,1,4 Other Resources/Approac^ "'luinyStor lanagement
In addition to more traditional funding sources discussed previously, there are new and evolving
approaches to funding stormwater management that could be leveraged in many cases. These include
public/private partnerships, private site stormwater development, and volunteer programs. The ability
to utilize such approaches, and the impact to the stormwater program vary but are important options to
evaluate in developing a comprehensive funding strategy.
5.2.2.2 One-Time Sources
A wide variety of one-time grants are available for supporting specific initiatives of capital projects from
government and private foundation sources. The advantage of such grants is that there is no repayment
requirement and the amounts can be substantial. The disadvantages include the competitive nature of
the grants, the requirement for pre-positioned matching in-kind or funds for some grants, the
limitations on the use of some grant funds, the effort required to file the applications, and the need to
harmonize the grant requirements with the needs of the local government.
There are several federal and state grant programs, including both ongoing programs and one-time
opportunities. A number of websites provide a good source for learning about federal grants: sites for
agencies that participate in the water world will present many opportunities, as will http://grants.gov.
For example, the 1987 amendments to the Clean Water Act established the Section 319 Nonpoint
Source Management Program. Under Section 319, states, territories and tribes receive grant money that
supports a wide variety of activities including technical assistance, financial assistance, education,
training, technology transfer, demonstration projects and monitoring to assess the success of specific
nonpoint-source implementation projects. Grantees must use these funds to implement U.S. EPA-
approved nonpoint-source pollution management programs. A 40 percent nonfederal match, in the
form of supplies, equipment, and/or funding, must be provided by grantees. Regulatory and
27 U.S. EPA. 2019. "319 Grant Program for States and Territories." https://www.epa,gov/nps/319~grant~program-
states-and-territories
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approved by the chartered EFAB, and does not represent EPA policy.
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nonregulatory programs assessing the success of specific nonpoint-source pollution control projects may
be eligible for these grants. Grant totals for the last few years were in the $170 million range.28
Many types of foundations and charitable organizations have begun supporting various aspects of
stormwater-related needs through grant-making. Foundation and corporate grants are a significant and
growing source of funding for environmental protection projects. Most grants of this type fund well-
defined projects, with specified time frames, costs and deliverables that meet the immediate priorities
of the funding source and are not funded by governments. Foundation and corporate grant programs
tend to favor the most innovative environmental projects. Funding such things as green infrastructure
strictly through grants generally is not a sustainable financing strategy, but it may be a way to fund some
high-profile demonstration projects that will attract subsequent sustainable government or property-
owner financial support.
5,2,3 Other Resources/Approaches' siurr nagement
In addition to more traditional funding sources discussed previously, there are new and evolving
approaches to funding stormwater management that could be leveraged in many cases. These include
public/private partnerships, private site stormwater development, and volunteer programs. The ability
to utilize such approaches, and the impact to the stormwater program vary but are important options to
evaluate in developing a comprehensive funding strategy.
5.2.3.1 Public-I rfne
Public-private partnerships (P3s) are receiving increasing attention in the United States and
internationally as an innovative way of financing a wide range of different environmental protection
initiatives. The point of P3s is that partnering with private enterprise can expand access to resources and
capital and offer better economies of scale. There are many types of P3s: design/build,
design/build/operate/maintain, pay-for-performance (interchangeable with pay-for-success),
community-based P3s, etc. They may include private financing or a combination of public and private
financing. Community-based P3s have a "commitment to social goals through setting robust
requirements for local jobs, and providing a platform for economic growth and revitalization associated
with large-scale Gl investments. Additionally, in this framework (based upon the military housing private
investment model), the community benefits through the structure of the community-based public-
private partnerships (CBP3) to reinvest savings through efficiencies in implementation back into more
'greened' acres rather than simply taking the savings as profits realized. Interest in CBP3s has been
growing across the country, as there is recognition of the universal applicability of this approach."29
In some cases, it is possible to capitalize on specific private sector resources through the use of P3s. The
availability of those resources depends upon the nature of the partnership arrangements, the resources
28 U.S. EPA. 2019. "319 Grant Program for States and Territories." https://www.epa,gov/nps/319~grant~program-
states-and-territories
29 California Stormwater Quality Association. 2019. 'The Community-Based Public-Private Partnership Approach: A
Revolution in Funding and Financing Green Infrastructure." https://www.ca sqa.org/asca/communitv-based-public-
private-partnership-approach-revolution-funding-and-financing-green
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available to the private partners, the circumstances in the locations where they are set up, and other
factors. Access to sophisticated technologies and specialized expertise often allows the private sector to
provide specific types of services that the public sector may be unable to provide. In addition, private
financing can reduce the burden on public debt capacity. Private sector procurement and construction
methods sometimes save time and provide significant cost savings. Through P3s involving ownership
transfers from government entities to private companies, responsibilities for financial risk can be
transferred from the government entity to the private company.
P3s have some important limitations. Local governments may not always have the legal authority to
enter into contracts with private parties. A government jointing a P3 might lose oversight
opportunities—a major concern. When government officials cease to be involved with the day-to-day
operations of a facility, they may have to give up opportunities to monitor things such as compliance
with environmental standards and permits. In addition, public employees and unions may oppose the
use of P3s due to concerns about the loss of jobs. Finally, tax-exempt and/or other low-cost financing
that is available for (federal and state) government-run projects may not be available for P3s.
Thus, the appropriateness of a particular type of P3 for a given environmental protection initiative and
location depends on many factors, such as the type of environmental media being protected, availability
of public funding for the partnership, demographics, and the tax code.
5.2.3.2 Volunh
Volunteers can provide free labor for a variety of local stormwater program efforts. Examples include
education, technical assistance to homeowners, inspections, cleanups, adoptions of various stormwater
systems and rivers, grant writing, watchdogs, and more. Volunteers and volunteer organizations can
bolster support for stormwater programs or funding approaches. Citizen groups can assist in decision-
making and in selling decisions to the public. River-keeper-type groups can provide a sense of
stewardship of precious water resources and can serve as great allies with local governments. Some can
help run and manage programs such as rain gardens, citizen monitoring and stream cleanups.
Some volunteer groups require significant supervision and training for the perceived return on
investment, and there can be safety and liability concerns when volunteers partner with local
governments for activities.
An approach that can reduce or eliminate these problems is adoption of stormwater management
features: cases in which a group or company adopts a street, detention facility, pond, greenway or other
feature in the same way a company adopts a stadium in return for naming rights. Signage can be placed
along a road or near another feature with the adopter's name and/or logo. Such has been done by
Boeing and Starbucks.
While volunteer programs do not mitigate a substantial cost of the overall stormwater program, they do
provide valuable services and also help to engage the community and can be helpful in gaining public
understanding of stormwater management needs in the community.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
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approved by the chartered EFAB, and does not represent EPA policy.
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5.2.3.3 Coordination with Other Community Departments
Synergies can be gained among agencies that influence some aspect of stormwater management when
they cooperate, when a better-funded department or agency provides funding or services to a
stormwater program. Examples include:
i A solid waste agency providing household hazardous waste assistance
§ A wastewater agency working to eliminate seepage of wastewater into the stormwater system as
part of an l&l program
A A public affairs office helping the stormwater program implement certain activities
~ An agency that bills for service providing inserts explaining some aspect of the stormwater program
A public works or transportation department can add stormwater components or green infrastructure
features as a small part of a construction project. This can even work with different agencies or at
different levels of government.
Outside programs or organizations can incentivize such partnerships (e.g., watershed groups spanning
several local governments or DOT's) through coordination and funding efforts.
5.2.3.4 Market-Based So.
Local and state agencies, often in collaboration with EPA, have created market-based solutions to tackle
various water quality challenges—including nutrient reduction, volume control and wetland mitigation,
among others. These markets are designed to attract private capital, take advantage of efficiencies
gained from private delivery of projects, and/or direct solutions geographically to where they are
needed most. An internal EPA memo from February 6, 2019, reiterated the agency's support for market-
based solutions, particularly for nonpoint-source pollution (i.e., stormwater), and provided clarity to
state and local regulators and policymakers on best practices to implement locally appropriate
solutions. The most common form of market-based solution is through the creation of a credit or unit
of measure that denominates and quantifies an environmental outcome against a specific regulatory
mandate (e.g., Total Maximum Daily Load). The supplier of a credit is typically a non-regulated private or
public entity that has the financial wherewithal to build a project or a regulated entity that can go
beyond what is required of it. In both cases, this supplier generates additional environmental capacity
that can be sold to offset a regulated private or public entity's regulatory requirements. A functioning
market will have many buyers and sellers and a dynamic price based on what the market will bear.
Examples include wetland mitigation banking, nutrient trading, and stormwater volume trading. The last
of these, stormwater volume trading, is an emerging local solution pioneered by the District of
Columbia's Department of Energy and the Environment and profiled in a case study in Appendix II. It
30 U.S. EPA. 2019. Updating the Environmental Protection Agency's (EPA) Water Quality Trading Policy to Promote
Market-Based Mechanisms for Improving Water Quality, https://www.epa,gov/sites/production/files/2019-
02/documents/trading-policv-memo-2019.pdf
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approved by the chartered EFAB, and does not represent EPA policy.
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involves purchase of "Stormwater Retention Credits/' seen as more cost effective for regulated property
owners or developers but equally effective in attainment of the District's regulatory standard.
* Advantages:
o Create cost efficiencies in placement of stormwater controls.
o Can allow for aggregation for better overall
control and treatment.
o Can shift and target controls to more critical
locations and be combined with other
public incentives (e.g., grant programs) to
further incentivize credit suppliers to
develop projects in specific places.
* Disadvantages:
o Can be complex to administer
o Require clear and enforceable policies on
ownership and maintenance.
o Markets may be not be initially viable and
may need to be jumpstarted with local
funding.
5.2.3.5 Newer Innovative Approaches
Market-based solutions are just one of many new
approaches that can attract new forms of funding and
financing. A wide variety of approaches that seek to
exploit unique or unusual funding sources are being
explored in the stormwater space. Examples include:
* Sponsorship of stormwater or green infrastructure
sites by private and/or public organizations, similar
to adopt-a-road advertising.
* Tax increment financing that can be leveraged if a
new green infrastructure facility is designed to
increase surrounding property values, owners of
those properties agree to a new tax levy, and an
agency is designated legally to issue tax increment
bonds.
* Use of private land for public infrastructure through various partnership and payment mechanisms
between public agencies and private landowners.
* "Complete" or "green" street policies that mandate road repairs and include stormwater
management, often combined with vegetative practices or other aesthetic improvements.
Case Study: Washington, D.C.
Stormwater Retention Credit
Training
The U.S.' First Stormwater Retention
Trading Market in the Nation's
Capital
In 2013 Washington, D.C.
promulgated new stormwater
retention regulations for new
development or substantial
improvement projects. Part of these
new regulations was the
introduction of the Stormwater
Retention Credit Trading market,
which allows these regulated
projects to purchase up to 50% of
their stormwater management
requirements off site, in the form of
Stormwater Retention Credits (SRCs).
This allows regulated properties to
pursue more cost-effective
compliance methods and provides
financial incentives for properties to
voluntarily install stormwater
management practices.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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i User fee credits that incentivize reduction in impervious area.
§ Green ratio ordinances that require developers in certain zoning districts to dedicate a percentage
of their property to natural area, which can manage stormwater runoff.
A Various development incentives, including floor-area-ratio bonuses, expedited permitting, and
others in exchange for voluntary construction of stormwater management practices.
~ Strategic partnerships between communities and philanthropic sources to enhance public spending.
# Advantages:
o Can provide funds at little cost.
o Can motivate the private sector through name recognition.
o Can provide good return on seed money investment when paired with private actions.
i Disadvantages:
o Can be hard to administer and explain,
o May require opinions and analysis on legality.
5.3 Availability of Funding
The previous section describes the different types of funding sources for stormwater programs. Even
though there are several sources of funding, it is important to recognize several challenges that exist
when evaluating the overall stormwater funding aspect of stormwater management. In addition, only a
few funding sources can provide reliable, sustainable, and dedicated revenue for stormwater programs.
In fact, about 60 percent of the respondents to a recent survey indicate that their top challenge is the
lack of funding or availability of capital for their programs.31
5,3,1 .: ;s by >f Funding
i User Fees: User fees, as discussed earlier, can provide a reliable, sustainable and dedicated revenue
mechanism for stormwater programs. However, many communities need expertise, resources,
financial assistance to even plan for, develop, and launch a user fee program. Perhaps more
importantly, any public initiative to enhance stormwater funding cannot happen without the
engagement and acceptance of citizens within a local community and the support of local elected
officials.
In addition, the level of funding, which utilities that do have dedicated user fees or dedicated
stormwater tax type fees generate, is not adequate to meet all of the stormwater community needs.
31 WEF Stormwater Institute. 2019. National Municipal Separate Storm Sewer System (MS4) Needs Assessment
Survey Results. https://wefstormwaterinstitute.org/wp-content/uploads/2019/08/MS4-Survey-Report-2019.pdf
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i Debt Financing: Despite the benefits of debt financing discussed earlier, the challenge that majority
of the communities currently face in leveraging debt financing, is that they simply do currently do
not have the annual financial capacity to repay the debt service associated with debt financing.
Consequently, stormwater programs have not leveraged capital financing sources to the extent
available. This is primarily due to the lack of a sustainable, recurring funding source to provide the
funding necessary for repayment. According to the 2018 Black & Veatch Stormwater Survey, only 13% of
stormwater utilities responding to the survey indicated that the majority of their capital program is debt
financed. 87% indicated that the majority of the capital program was cash funded. Therefore, it seems
that even where stormwater utilities (with user fees) are in place, communities are not leveraging
capital financing vehicles to the extent available.
~ Grants: Many of the grant programs are predominantly focused on specific regions (e.g.,
Appalachian Regional Commission, Region 1 Healthy Communities Grant Program, etc.); specific
type of demographics (e.g., Special Evaluation Assistance for Rural Communities and Households,
Clean Water Act Indian Set-Aside Grant Program, etc.); or specific activity (e.g., Beaches
Environmental Assessment and Coastal Health Act Grants. Hence, not all communities nation-wide
have access to grants.
Further, in most cases, grant allocations are much smaller in magnitude, and are also limited to a certain
percentage of the overall project, with matching funds required. The qualifications for each program
vary, depending upon the requirements of the specific program. In addition, normally, grants have a
window of opportunity to apply for funding each year, with the total amount available dependent upon
the level of appropriation for the year.
i Public-Private Partnerships & Market Based Solutions: Many of the capital financing sources such
as Public-Private Partnerships, Market Based Solutions, and other such programs are still in their
infancy or just emerging, and may not be a viable option especially for smaller and rural
communities.
§ Volunteer Programs: While programs such as volunteer programs are a beneficial tool in the overall
stormwater management, those cannot contribute in any material manner to bridge the significant
funding adequacy issues that many communities face.
5,3.2 Estimate ol icatecl Stormwater Recurring Revenue Generation
Currently, there is no robust tracking of the annual revenue that is currently generated in the United
States from even the annually recurring and dedicated stormwater revenues sources discussed earlier in
this section. However, there are a couple of national level surveys that have gathered information on
annual revenues generated by stormwater utilities that have a dedicated stormwater user fee.
Therefore, the EPA the task force attempted to leverage the annual revenue information available from
(i) the 2019 Western Kentucky University (WKU) survey on stormwater utilities, and (ii) the 2018 Black &
Veatch Stormwater Survey of utilities that have stormwater user fees.
Out of the 1,700+ stormwater utilities from which WKU gathered user fee, population, and annual
revenue information, the annual revenue data was available only for 678 of those 1,700+ utilities. Based
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on this available information, the median annual stormwater user fee revenue per capita was
determined to be $32.00. To the contrary, based on the annual revenue information that survey
participants reported in its survey, Black & Veatch reported a median annual stormwater user fee
revenue per capita of $54.00.
As at the time of this EPA Task Force study and report preparation, only these two sources of
information were available, the EPA Task Force deemed it appropriate to extrapolate the potential
annual revenue generation from existing 1,700+ stormwater utilities. The 1,700+ utilities identified in
the WKU survey, encompass a total population of roughly 114,850,631. So, using the median annual
revenue per capita figures determined from the two surveys, the following low end and high-end range
of annual revenue generation is estimated, at the current time, from the 1,700+ stormwater utilities
nationwide:
i Low end annual revenue generation estimate: 114,850, 631 * $32 = 3.675 Billion (rounded)
i Low end annual revenue generation estimate: 114,850, 631 * $54 = 6.202 Billion (rounded)
This annual revenue generation range off $3,675 to $6,202 Billion is based on the extrapolation done on
a per capita basis from the 1,700+ stormwater utilities.
However, the annual stormwater revenue generated from dedicated recurring funding source will be
higher as there are also a few utilities nationwide that have dedicated stormwater taxes and other
stormwater special assessments discussed earlier in this section. Currently, there is no readily available
information on the revenues generated from these other dedicated stormwater revenue sources, and
hence it is not feasible to estimate the aggregate annual stormwater revenues that are generated
overall from the existing revenue sources that are explicitly dedicated to stormwater management.
However, it is important to note that the revenue from dedicated stormwater funding sources such as
taxes, special assessments, etc is likely to be not significant as not many utilities in the country have
these types of dedicated stormwater revenue generation mechanisms.
Based on the annual stormwater revenues estimated just from the user fee revenues of 1,700
stormwater utilities, it is evident that there is an enormous "funding gap" between the overall
stormwater management funding needs and the level of funding that appears to be currently generated
in the United States. As described in Section 4.8 of this report, the funding gap is estimated to be
approximately $ 8 to $10 billion annually. This number is based on a national scale survey conducted by
the Water Environment Federation's Stormwater Institute in 2018. The information was obtained from
MS4 permittees to determine the total annual funding gap for stormwater programs (MS4 compliance
activities only) nationally.
To address this funding gap, diverse types of proactive measures including Federal, State, and Local
legislative actions and policies; enhanced technical and financial assistance; significant public education
and engagement; and a drive towards establishing dedicated sources of stormwater funding at the local
level, are necessary.
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5.4 Barriers to Obtaining Funding
Previous sections summarize the plethora of funding opportunities for stormwater programs. However,
this discussion would not be complete without mention of the many barriers to funding stormwater
programs in any meaningful way. As with most public funding schemes, there is a tension between the
need for funding and the access to funding—as well there should be in a public arena. Blank checks do
not exist, nor should they. But the barriers are often substantial, and thus stormwater programs across
the country are experiencing such a huge gap between needs and available funding.
This section focuses on barriers to funding from recurring, sustainable sources (such as taxes and user
fees), because they form the backbone of any funding portfolio and can be the most difficult to secure
at required levels.
5.4.1 Political Decision Making
A key principle in public governance is that it is done with the permission of those governed. Financial
support for publicly funded programs and services cannot be effectively established without substantial
buy-in from the members of the community, and equally important without the legislative action of
local elected officials.
The most common political decision-making barrier stems from each community's local political
environment. Members of local governing bodies face a wide range of competing needs and are hesitant
to increase taxes and fees due to various political, economic, and constituent obligations reasons,
reasons (not least the desire to be re-elected). The local decision makers typically refrain from proactive
stewardship for establishing a new source of funding such a new stormwater user fee or for enhancing
existing stormwater fees and charges, especially when the community has significant stormwater
management needs and the associated need for significant funding. There are many drivers for political
barriers including public perception, historical context of stormwater management and funding,
competition from other public programs, and a general cynicism for any new proposal for taxes or fees.
To garner effective support from local decision makers, stormwater program managers must engage in
extensive and timely education of its public and elected officials, and thoughtfully plan and prioritize
O&M and capital program investments so as to maximize benefits community-wide over the planning
horizon, community members and elected officials in the overall running of programs as well as
establishing funding structures.
5.4.2 Public Per
Across the United States, there is general fatigue from taxes, fees and charges, particularly for utility
bills when water and sewer bills seem to increase much faster than other household costs. This often
translates to cynicism and limits the ability to garner stakeholder support for a new user fee or tax. The
lack of support intensifies when the population is not familiar with stormwater program and funding
needs, and don't have a clear understanding of the potential and tangible community-wide benefits.
In addition, stormwater management is often not seen as an essential service. As with water and sewer
utilities, the average citizen may not be aware of the complex network of stormwater drainage system
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or how it enhances their quality of life, safety, and, potentially, property values. In many communities,
chronic system failures may only be evident as a minor nuisance such as intersection flooding. In
addition, other common property services such as water, sewer and garbage collection have been
historically seen as essential public health services—but not stormwater management. The average
citizen actively turns on the kitchen sink faucet, flushes toilets, or puts the garbage out at the curb once
a week; stormwater services are much more passive. So it is not surprising to find a general lack of
understanding about stormwater systems.
This is the setting in which a municipality or utility may ask for a new stormwater user fee or some other
source of funding (e.g., a sales tax dedicated to stormwater). When the issue of stormwater funding and
user fee is initiated in such an environment of limited public awareness and perception, the road to
successful funding becomes challenging.
5.4.3 Competing Needs
Municipalities are one of our most potent forms of government, providing the widest array of public
services to their citizens. These typically include police, fire, parks and recreation, roads, utilities,
libraries and other facilities, and other general social services. Stormwater programs and facilities
compete for public funds in this crowded field. Whether through strategic planning, annual budget
requests or electoral politics, stormwater service is often prioritized much lower than other municipal
services.
5.4.4 Legal Barr g
Funding for public programs must comply with a variety of legal requirements, many of which are noted
in previous sections of this report. In some cases, these legal requirements can be barriers to developing
funding for stormwater programs.
5.4.4.' .. ts
Many states have legal restrictions that supersede a local governing body's authority for imposing a
stormwater fee. For instance, until a few months ago the State of New Jersey prohibited forming a
stormwater utility or imposing fees. (The state's governor has now signed legislation giving that
authority to municipalities.) In 1996, meanwhile California voters approved Proposition 218, a
constitutional amendment making it more difficult for local government to impose taxes, fees and
assessments. One provision (clarified in a 2002 court ruling32) requires stormwater fees to be submitted
to a ballot measure requiring either a 50 percent majority of affected property owners or two-thirds
majority of registered voters to impose (or increase) a stormwater fee. Since 2002 only 31 stormwater
32 California Sixth Appellate District, Howard Jarvis Taxpayers Association versus the City of Salinas, 2002. That
decision acknowledged that Proposition 218's text is ambiguous as to whether stormwater falls under the
definition of "sewer," which did not have the ballot requirement. In 2017, the California Governor signed SB-231,
clarifying that definition to also exempt stormwater fees from the ballot requirement. The Salinas plaintiff has
vowed to sue any municipality that sets fees accordingly. However, the threat of litigation alone has caused most
cities to continue to take fees to the ballot.
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ballot measures have been pursued statewide (among more than 500 municipalities); voters have
approved about two-thirds of them.
Overall, 41 states and the District of Columbia have at least one stormwater utility each. The other nine
states have none, and legal barriers may play a part in that.
5.4.4.2 Legal Challenges
Legal challenges of new stormwater fees are a concern to many municipalities, particularly small ones
that are limited in the resources needed to sort through complex and sometimes ambiguous enabling
legislation. "Such is the case in Pennsylvania where regional approaches are being pursued in the
counties of Blair, York, Lancaster and Montgomery, but, even there, one of the major barriers to
implementation is concern about the confusing details of the enabling legislation and fear that
implementation won't confirm and will be mired in legal challenges."
Legal challenges do occur. Previously mentioned was the Salinas case in California, which significantly
changed the stormwater funding landscape in that state. The Western Kentucky University Stormwater
Utility Survey from 2013 summarized legal challenges across the country. "We have now identified 76
legal or political challenges to stormwater utilities in the U.S....Of the 76 challenges, 44 were decided in
favor of the utility, while in 16 cases the utilities received unfavorable decisions or were struck down.
Twelve of the cases are still pending or we were unable to find whether or not a court decision had been
reached. Five challenges were successful political challenges. Stormwater utilities in Birmingham,
Alabama, Colorado Springs, Nampa, Idaho, Manitowoc, Wisconsin, and in Cumberland County, North
Carolina were repealed." '
The 2018 edition of the Black & Veatch Stormwater Utility Survey" asked the 75 participating agencies
whether their stormwater user fees ever faced legal challenges. They found that 27 percent of the
respondents said "yes." The basis of challenge varied as follows:
# Tax and not a user fee (38 percent)
# Lack of authority to assess stormwater fees (24 percent)
i Equity and fairness (17 percent)
# Rate methodology (14 percent)
i Rational nexus between costs and user fees (3 percent)
# Constitutionality (3 percent)
33 Environmental Financial Advisory Board. 2016. Developing Dedicated Stormwater Revenues.
34 Campbell, C. W. 2013. Western Kentucky University Stormwater Utility Survey 2013.
httpsi//www,wku,edu/seas/documents/western kentuckv university swu survey 2013.pdf
35 Black & Veatch. 2018. "Stormwater Rate Structure and Billing." In 2018 Stormwater Utility Survey.
httpsi//www,bv,com/sites/default/files/2019-
10/18%2QStormwater%20Utility%2QSurvey%20Report%20WEB O.pdf
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5,4,5 Equity Issues
As many as 92 percent of stormwater utilities base their fees on relative impervious surface area.36 This
is a well-accepted method to ensure fair distribution of costs to customers, one of the distinguishing
features of a user fee (as opposed to a tax). An unintended consequence of that fee basis is the
potential of a disproportionate financial burden placed on properties in disadvantaged areas. Residential
densities tend to be higher, which is often accompanied by a much higher percentage of impervious
surfaces (and thus a higher proportion of the fee base).
Low-income areas also tend to be in low-lying, flood-prone areas where insufficient stormwater capacity
is first felt. These neighborhoods also tend to be rental properties where landlords have little incentive
to invest in green spaces or low-impact development.
Rate discounts or exemptions for low-income or seniors are sometimes difficult to provide. With no
rational basis for reducing rates based on impervious surface, some states do not permit such discounts
unless subsidized by non-stormwater funds (such as a city's general fund).
5,4,8 Administrative
Sometimes the greatest barrier to forming a stormwater utility is the agency's internal administrative
structure. This is particularly true for local municipalities where various stormwater functions have
evolved within different departments or divisions. For example, infrastructure maintenance may reside
in the streets or sewer departments, NPDES compliance in the environmental group, capital planning in
the engineering division, and financial services in the finance department. In other words, it is all too
common to find these functional units distributed throughout a municipal organization without unified
leadership or cohesive functionality.
Without such leadership, it can be very difficult to champion a cause such as initiating a stormwater user
fee. Support for change must often come from senior management in order to be implemented.
5,4,7 . j Re
Managing a complex municipal utility requires significant resources that are often lacking—particularly
in small/midsize municipalities or ones that are attempting to launch a stormwater utility structure for
the first time. These resources may include:
# Strategic and financial planning
# Asset management
# Technology (GIS, data)
# Public engagement (branding, outreach)
The path to a dedicated and sustainable revenue stream includes all of the above (needs analyses,
financial planning, fee study, community engagement). This can cost $300,000 to $1 million or more and
36 Ibid.
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take two or more years. In addition, competing in the grant funding arena demands that a stormwater
agency possess expertise in grant writing and grant administration.
Finally, basic NPDES permit compliance is a complex and time-consuming endeavor to which an MS4
must devote resources to keep abreast of changing regulations and implementing NPDES programs,
public education and enforcement.
5,4,8 Lack of Public/Policymaker Awareness arid Understanding of Needs
The first step in establishing a stormwater utility is determining the needs and calculating the associated
costs. Once done, the bigger challenge may be communicating this need to the municipality's
policymakers and the community at large in a compelling way. "The most effective stormwater business
plans recognize community expectations. In some cases, expectations must be elevated by convincing
demonstrations that stormwater problems exist and can be solved. Stormwater management rarely
captures public support unless problems impact the daily lives of citizens. Many drainage systems are
underground and essentially invisible to the public. If they are designed, constructed, and maintained
properly, most people are unaware of them. More visible problems such as potholes in roadways
consistently rate higher than drainage problems. The most effective programs identify and publicize the
problems they must address, seek public participation and support, and orchestrate the use of various
tools and resources over time."37
This can be accomplished from the technical side with engineering and financial analyses. But moving
public opinion is much more difficult and requires expertise not often found in the ranks of stormwater
managers. A successful utility would employ public information personnel and develop an early branding
effort from which is built a full public engagement program that can begin to move the opinion of both
policymakers and the public at large.
5.5
Stormwater programs face many challenges to developing the resources needed to deliver programs, as
well as the projects that will achieve the goals of flood protection and clean water. Progress has been
made on many stormwater funding fronts, including many federal and state grant programs. While
primary funding remains a local municipal responsibility, it is widely recommended that any stormwater
program or utility develop a portfolio approach to funding. A solid foundation for that portfolio should
be a dedicated, sustainable revenue stream such as user fees, but it should be supplemented with a
robust array of other funding and financing mechanisms such as loans and other debt tools, grants,
partnerships, and multiple creative approaches using the resources of other like developers and private
interests.
The role of the federal government may be limited by comparison, but its presence is invaluable in
helping provide much needed capital funding for large projects, as well as in providing education,
37 National Association of Flood and Stormwater Management Agencies. 2006. Guidance for Municipal Stormwater
Funding.
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offering training, and making all opportunities to meet the challenges of funding available to all local
programs.
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6.0 Infrastructure Affordability
Identify how the source of funding affects the affordability of the infrastructure,
including consideration of the costs associated with financing the infrastructure.
Section 5.0 of this report details the types of funding sources and financial resources that are and could
be used to manage stormwater operations and infrastructure. It also presents an overview of the key
barriers municipalities face in obtaining the requisite ongoing funding for effective stormwater
management. This section of the report focuses on how the funding sources affect three aspects of a
municipality's stormwater management capabilities and household affordability: efficient management
of infrastructure, financial capability, and customer household affordability.
6.1 Infrastructure Efficiency
An integral and critical aspect of stormwater infrastructure management is how efficiently utilities
manage stormwater infrastructure. Generally, infrastructure efficiency pertains to a deliberate focus on
best practices such as proactive asset management, effective use and leveraging of resources, strategies
that help achieve economies of scale, and risk mitigation and resiliency building efforts. An area of
opportunity identified by the Task Force is the highly decentralized nature of stormwater service
provision.
The types of U.S. stormwater systems and the organization of responsibilities both significantly influence
infrastructure efficiency. The following subsections discuss these two issues.
6.1.1 Types of Stormwater Systems and Implications
Stormwater is discharged not only through MS4 conveyance infrastructure but also via CSS conveyance
infrastructure. MS4s and CSSs have similar obligations under the federal Water Pollution Control Act of
1972 (P.L. 92-500), commonly known as the CWA, and its related amendments. However, the two
systems' characteristics impose unique levels of service and infrastructure management burdens and
obligations, and consequently exert differing levels of impact on infrastructure efficiency, financial
capability and customer affordability.
Excessive wet weather (stormwater) flows in a CSS could trigger combined sewer overflows (CSOs),
where the untreated combined stormwater and sanitary sewage is directly discharged to surface
receiving waters without even primary treatment. Consequently, the environmental responsibilities and
exposure to regulatory mandates such as the Long Term Control Plan (LTCP) requirements for CSS can
be vastly more expensive, as measured in both operating expenses and capital commitments necessary
to eliminate CSOs. Further, stormwater inflow into non-CSS wastewater collection systems can cause
similar overflows conditions.
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Excessive wet weather flows also affect MS4s in a number of ways, including flooding, habitat
degradation, streams and channel erosion, and other significant water quality issues such as
sedimentation and pollution resulting from stormwater runoff. These, in turn, create the need for
stormwater treatment facilities.
Both CSSs and MS4s involve significant financial investment in the treatment and management of wet
weather flows. Typically, funding for CSS management is covered by wastewater fees. Funding for MS4
management, the subject of this Task Force, is covered by a variety of sources as described in Section
5.0; however, many municipalities have no dedicated, consistent or reliable funding mechanisms in
place.
Regardless of the types of systems and funding mechanisms, customer affordability and the public's
understanding of the need for these services are critical.
8,1,2 Delineation of Stormwater Resf bs
The Task Force has observed significant differences among municipalities with respect to the
distribution of stormwater management and regulatory compliance responsibilities. Some of these can
be attributed to the types of stormwater management systems that exist within a jurisdictional area
(discussed above); largely, though, they can be attributed to the institutional framework established by
the state in which the municipality is located, as well as local and regional stormwater needs. The
distribution of responsibilities can affect affordability by creating situations where there are overlapping
responsibilities and limited accountability for program implementation.
In some municipalities (e.g., Philadelphia, Pennsylvania, or Newark, New Jersey), the water/sewer
utility—a city department—is responsible for managing all aspects of stormwater management
including LTCP/ NPDES and MS4 regulatory compliance; both CSS and MS4 types of stormwater
infrastructure; and all associated O&M requirements, including green infrastructure initiatives. In these
cases, the management of the entire stormwater infrastructure rests within a single entity with single
point of accountability.
Responsibility is divided in other municipalities. In Washington, D.C., for example, an independent
authority (DC Water) manages the CSS and separate sanitary sewer systems while the municipality
(specifically, the Department of Energy and Environment) is responsible for all MS4 requirements. Even
in a municipality that has only an MS4 system and a separate sanitary sewer system, the stormwater
management responsibilities may be distributed between a water/sewer utility, a department of public
works, and for example a department of transportation. In addition, in many communities, the MS4
responsibilities for developing and implementing specific permit requirements such as stormwater
pollution prevention plans or nutrient management plans are given to school districts or fire, police or
parks departments. In these cases, holistic management of stormwater infrastructure requires a clear
understanding of roles and responsibilities, delineation of ownership of stormwater assets, and effective
coordination among the various entities to enhance infrastructure efficiency. An integrated planning
framework could especially enhance efficient management of infrastructure in these situations where
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multi-entity coordination is critical. Such a framework would put municipalities in a position to optimize
capital investments—making this a concept worth the investment of grant dollars.
Such significant differences in the distribution of stormwater service responsibilities among municipal
jurisdictions also directly influence the overall financial capability aspects of stormwater management
(discussed in Section 5.0), as funding and cost recovery mechanisms differ significantly. Note also that,
in some municipal jurisdictions, the U.S. Army Corps of Engineers may support the implementation of
stormwater-management-related projects (mainly large flood risk management projects) by providing
partial funding and technical assistance.
6.2 Financial Capability
Stormwater capital infrastructure investments are driven by the need to enhance and/or maintain
existing drainage capacity, flood mitigation, repair and rehabilitation of aging infrastructure, coastal
resilience, climate resilience, and community needs. In CSS communities with consent decree
requirements to mitigate CSOs, the pressure on stormwater infrastructure investments such as tunnel
or gray infrastructure, and/or the need to enhance pumping and wastewater treatment capacities, can
be significant. The critical challenges for a municipal entity managing stormwater infrastructure (for
CCSs or MS4s), are funding availability, funding adequacy and timeliness of funding.
Municipalities tend not to have enough funding for stormwater infrastructure, though they range on a
spectrum from "no dedicated funding" to "adequate funding." For example, the national WEF
Stormwater Institute and Black & Veatch stormwater surveys and other state-level stormwater,
drinking water and clean water surveys indicate that utilities cite "lack of funding availability" as their
highest-ranked challenge with respect to timely infrastructure investments. While there are many
funding sources for stormwater, as described in Section 5.0, the Task Force believes the funding is
inadequate and that there are significant barriers to accessing the available funding sources.
The following subsections present four factors affecting financial capability for effective stormwater
management:
~ Stormwater financial reporting
~ Impact of various funding sources on building financial capacity
A Implications of the financial capability assessment methodology
~ Customer household affordability
38 WEF Stormwater Institute. 2019. National Municipal Separate Storm Sewer System (MS4) Needs Assessment
Survey Results. httpsi//wefstormwaterinstitute,org/wp~content/uploads/2019/Q8/MS4~Survev~Report~2019,pdf;
Black & Veatch. 2018. 2018 Stormwater Utility Survey. httpsi//www,bv,corw/sites/default/files/2019-
10/18%2QStormwater%20Utilitv%2QSurvev%20Report%20WEB O.pdf
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8,2,1 Stormwater Financial Reporting
Stormwater infrastructure is, generally, an entirely municipal proposition. The footprint of publicly
traded investor-owned utilities and private companies that own and operate stormwater systems is
small—not a material share of the total infrastructure universe. Therein lies a major area of opportunity:
there are roughly 42,158 units of local government,39 and while not all are directly responsible for every
category of municipal asset, they are very diverse in management and governance structures as well as
financial reporting. This makes summary observations of financial capabilities as well as affordability to
households more difficult. Municipalities generally do not produce independently audited financial
statements with the same timeliness as publicly traded companies, nor do most publish intra-year
unaudited statements such as quarterly financials.
Specifically, the differences in management and governance have direct implications for stormwater
funding and financial reporting, as follows:
# General government (most common). When stormwater management responsibilities lie with a
general government (e.g., with its public works or streets and transportation department), the
primary source of funding is typically general tax revenues. There may not be any dedicated source
of funding for stormwater management. This governance and funding structure is usually associated
with a modified accrual basis of accounting or, worse, a cash basis. Neither includes a balance sheet
with assets and liabilities. Similarly, the statement of revenues over expenditures does not have an
explicit line item for depreciation for those assets that are even depreciable. The Task Force believes
that without a clear correlation between dedicated funding and revenue requirements, sufficient
funding for stormwater cannot be allocated through such governance structures.
A Utility department (varies by state, but generally less common). Some municipalities have
standalone stormwater enterprise funds. However, not all local governments have state statutory
authority to establish separate and discrete stormwater utilities, meaning stormwater management
responsibilities lie within the purview of a larger water and sanitary sewer utility department within
the municipality. The primary source of ongoing funding is typically user rates and user charges.
However, the way rates and charges are levied varies from municipality to municipality. Some
utilities (e.g., Philadelphia, Pennsylvania; Portland, Oregon; Wilmington, Delaware; and Chesterfield
County, Virginia) levy a fee based on the property's actual or estimated impervious surface area to
recover the costs associated with stormwater management. Other communities levy a flat recurring
charge based on type of land use (residential, commercial, etc.). Still other municipalities—such as
New York City, where the Department of Environmental Protection is responsible for water, sewer
and stormwater management—recover costs through sanitary sewer user charges. Still, for
transparency purposes, a rate-based funding structure typically is associated with traditional
enterprise financial reporting, using an accrual basis of accounting that does include an income
39 Hogue, C. 2013. Government Organization Summary Report: 2012.
httpsi//www,census,gov/content/dam/Census/library/publications/2013/econ/gl2-cg-org,pdf. (This Census
summary identifies 38,910 general purpose governments. It excludes special and school districts but does include
3,248 special districts categorized as "drainage and flood control.")
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statement, balance sheet and depreciation. This makes it less difficult to assess whether ongoing
funding is sufficient to cover stormwater needs, even without uniform reporting standards.
§ Independent authority (least common). If stormwater management responsibility lies with an
independent municipal authority or separate political subdivision, stormwater funding may have to
rely on either the taxing authority or its own rates and charges. Comparability and assessment of
financial capacity and affordability to the household is therefore subject to financial accounting and
transparency.
6,2,2 Impact of Various Funding Sources on B incial Capacity
The Task Force reviewed the key funding sources discussed in Section 5.0, evaluating most of those
sources' potential impact on a municipal entity's overall ability to build financial capacity, for O&M and
capital infrastructure investment.
In the summary below, the Task Force discuss the criteria for this review, summarize the findings and
present a case study examples.
6.2.2.1 Assessment Crifei *
The Task Force defined the following key criteria for evaluating the ability of various funding sources to
help build a municipality's overall financial capacity:
i Sufficiency—measures the total annual revenue that a municipality can generate from one or more
funding sources.
§ Stability/sustainability—assesses the ability of the combination of funding sources to provide
consistent and reliable levels of dedicated funding to support immediate and long-term sustained
infrastructure management including capacity expansion and to meet O&M service obligations.
These criteria also measure the sustainability of the revenue source.
i Scalability—measures the flexibility of the utility to increase funding commensurate with increases
in revenue requirements.
# Legislative requirements—funding options including user fees, impact fees and debt issuance often
require internal approval from boards, councils or commissions, and/or potentially voter
approval/referenda through ballot measures. These legislative requirements and challenges can
influence the ability to generate timely funding.
A Acceptability—evaluates the benefits and risks of the various funding sources as judged by elected
officials, utility management and external stakeholders.
~ Customer equity—evaluates the measure of equity, which can be defined in a variety of ways, in
cost recovery from the customer base within the jurisdiction.
6.2.2.2 Summary Assessment of Funding Sources on O&M and Capital
Infrastructure Investments Financial Capacity
Section 5.0 summarized the various types of funding sources, along with their advantages and
disadvantages. It broke those sources into three categories:
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i Recurring and/or intermittent revenue funding
§ One-time funding sources for capital projects and/or one-time initiatives
i Other resources/approaches
This section further examines the impact of the first two of those categories in building a utility's
financial capacity for stormwater management.
i Figure 2 summarizes the impact of recurring and/or intermittent funding sources on a utility's ability
to effectively fund O&M operations. All of the sources listed in Figure 2 and Table 2 are applicable to
a municipal entity's stormwater O&M revenue requirements.
§ Figure 3 summarizes the impact of the one-time sources/initiatives on a utility's ability to
adequately fund capital infrastructure investments.
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Table 2. Financial Capacity Impact of Recurring/Intermittent Funding Sources—O&M Operations.
Evaluation
Criteria
Recurring or Intermittent "Revenue Based" Funding Sources
Taxes/General
Funds
Stormwater
Dedicated Taxes
Stormwater Utility
User Fee
Other O&M Fees
Surcharges or
Special Assessments
Revenue
Sufficiency
Low: general
funds typically
have different
priorities such as
public safety
Moderate: better
transparency via
correlation
between revenues
and revenue
requirements
Moderate to high:
generally, the rates
and charges are
objectively aligned
with the revenue
requirements of the
stormwater system
Low: don't always have
a clear correlation or
justification to annual
revenue requirements
and may be fungible
with other general
government needs
Moderate: generally,
have somewhat
limited revenue-
raising ability
Stability of
Revenues
Volatile: property
and sales tax
bases can rise and
fall with economic
cycles
Volatile: property
and sales tax bases
can rise and fall
with economic
cycles
Strong: revenues are
tied to either the size
of the property's
impervious surface
area or the category of
the property, not to
economic cycles
Variable: very low
volatility if tied to a per-
parcel fee and not
subject to property
valuation, very high
volatility if tied to non-
recurring cash flows like
development
Low to moderate:
special assessments
often are tied to
property valuation
and surcharges
sometimes are
related to water
consumption
Scalability to
Meet
Increasing
Needs
Low: major line
item increases are
generally subject
to political
scrutiny
Very low:
dedicated taxes are
typically voter-
approved and may
not even exist in
perpetuity
High: a dedicated
funding source allows
the user fees to be
leveraged to address
both O&M and capital
expenditure; however,
fee increases are
typically not well
received by elected
officials or the public
Low: would mostly
likely need some kind of
authorization to scale
up the fee structure,
from a municipality or
even a homeowners'
association
Moderate: limited
ability to increase
revenues creates
finite financial
capacity
Legislative
Requirements
High: subject to
annual
appropriation,
sometimes even
voter approval
Very high: subject
to voter approval
and annual
appropriation
Low: usually only
requires a one-time
authorization via
either state general
assembly or municipal
ordinance
Very high: subject to
voter approval and
annual appropriation,
perhaps public
education to get buy-in
from the developer
community
High: likely subject to
some kind of initial
legal authorization
Community
Acceptability
High: aside from
politicization of
where in the
municipality to
fund projects,
usually not
controversial
Moderately high:
establishing a new
tax may not be
politically palatable
unless a recent
flood event is
driving the measure
High: aside from
politicization of where
in the municipality to
fund projects, usually
not controversial
Moderately high:
establishing a new tax
may not be politically
palatable unless a
recent flood event is
driving the measure,
but possibly offset by a
user-pay
Moderately high:
establishing a new
tax or fee may not be
politically palatable
unless a recent flood
event is driving the
measure
Community
Financial
Capability
Barriers
High: many states
have established
and/or
municipalities
have self-imposed
limitations related
to taxation
Moderate:
comparably easier
to assess financial
capacity and assign
resources even if
that capacity may
be statutorily
limited
Low: a dedicated,
user-based, non-tax
revenue stream
creates dedicated
financial capabilities
and improves ability to
do multi-year planning
Moderate: if there is a
high degree of revenue
fluctuation, it may be
difficult to appropriate
funding to retain
dedicated full-time
equivalent staffing;
municipality could lose
institutional knowledge
Moderate:
comparably easier to
assess financial
capacity and assign
resources even if
that capacity may be
statutorily limited
Household
Affordability
Impact
High: property
taxes are generally
deemed as
regressive
High: property
taxes are generally
deemed as
regressive
Low: User fees are still
somewhat regressive
but usually much
smaller in actual
dollars compared to
water and sewer
charges
Low: if tied to a "user
pay" levy, would mostly
likely be borne by those
directly benefitting
from the infrastructure
Moderate: not as
regressive as a pure
tax but still
correlated to
property valuation
without explicit
income recognition
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leceptafei
•s ostori
Figure 2. impact of recurring and/or intermittent funding sources on a utility's ability to effectively fund O&M operations.
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not represent EPA policy.
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Sufficiency Cost of Borrowing flexibility in Use of Acceptability Financial Capability Affordability Impact
Impacts Fundi Barriers
OGrants OBonds Low-inter est Loans QCapital Revenue Fee O Developer Contribution
Figure 3. Impact of one-time sources/initiatives on a utility's ability to adequately fund capital infrastructure investments.
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Table 3. Financial Capacity Impact of One-Time Financing Sources—Capital Infrastructure
Evaluation
Criteria
One-Time Financing Sources for Capital Projects/Initiatives
Grants
Bonds
Low-Interest Loans
Capital Revenue
Fees
Developer
Contribution
Revenue
Sufficiency
Moderate: will
usually be
sufficient for a
single project but
rarely for an
entire system on a
recurring basis
Strong: allows for
payment over
extended period,
creating ability to pay
for larger projects and
still have cash flow for
ongoing O&M;
however, a dedicated
funding source is
needed to pay the
bond commitments
Strong: allows for
payment over extended
period of time, creating
ability to pay for larger
projects and still cash
flow for ongoing O&M;
however, a dedicated
funding source is
needed to pay the loan
Low: generally,
municipalities
earmark this revenue
stream for pay-as-
you-go infrastructure
investments, and
capital plan needs in
any given year may
exceed that
Low: generally tied
to economic
development or
redevelopment,
which can be very
volatile
Cost of
Borrowing
Impacts
Moderate:
typically requires
somefinancial
commitment or
cost share by the
municipality,
which is
sometimes itself a
barrier
High: interest
expense, ongoing
disclosure
requirements and
debt and financial
management
obligations recur
through the life of the
bonds
Moderately high:
typically rates are
subsidized and below
market; has fewer
disclosure and other
recurring requirements,
but still requires good
debt and financial
management practices
None: generally
municipalities
earmark this revenue
stream for pay-as-
you-go infrastructure
investments
None: one-time
cash inflow, against
which
municipalities
generally do not
borrow or pledge
toward debt
Flexibility in
the Use of
Funds
Low: federal and
maybe even state
grants require
single audit and
related
verification
High: if the bonds are
tax exempt, the main
restrictions are those
related to IRS
requirements
High: generally the only
restriction is that the
project must be
associated with the
lender agency's mission
Very high: local,
internally generated
revenues generally
do not have
restrictions
High: only
restriction might be
that contributions
be used for growth-
driven investments
in the immediate
area of
development
Legislative
Requirements
Almost none:
grants are well-
established tools
that may only
require formal
approval and
acceptance by the
municipality
Low: while some
states and many
municipalities impose
some guidelines or
limits, generally local
governments are not
restricted to use
bonds
Low to moderate: some
lending agencies
require more collateral
or a pledge of a
supplemental revenue
stream, which may
require further
authorization by the
municipality
Low: there may in
some states be a
requirement to
justify based on cost
of service
Low: political
willingness to
implement impact
fees (or equivalent)
is generally the only
barrier
Community
Acceptability
High: assuming
the local match is
not a barrier,
municipalities
generally
welcome grants
Moderate to high:
there may be some
aversion to debt in the
community but
generally this does not
preclude bond
issuance
High: federal or state
agencies may also be
more willing to work
with a financially
distressed community
than the capital market
creditors
Moderate:
introduction of fees
may be more
politically palatable
than taxes
Moderate: may
galvanize resistance
among the
developer
community as
being disruptive to
their business
model
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Evaluation
Criteria
One-Time Financing Sources for Capital Projects/Initiatives
Grants
Bonds
Low-Interest Loans
Capital Revenue
Fees
Developer
Contribution
Community
Financial
Capability
Barriers
High: many
communities lack
the institutional
knowledge or
funding for grant
application
writers and grant
administrators
High: generally
bonding relies on
access to credit
markets, which can be
a barrierto poor or
small municipalities
and requires good
financial management
Moderate: still requires
good financial
management practices
but federal and
especially state
agencies often can
provide technical and
administrative
assistance that small,
poor or rural
communities might not
otherwise be able to
access
Moderate:
recommended best
practices include
segregated financial
accounting and
reporting to show
citizens revenues are
being deployed as
represented—a
potential barrierfor
small, poor or rural
communities without
the requisite staff
Moderate: requires
financial and
technical expertise
to properly track
and account for
these non-recurring
revenues
Household
Affordability
Impact
Low: one of the
most favorable
weighted cost of
capital options
High: borrowing, even
at favorable interest
rates, is still the
highest cost of capital
Moderately high: few
programs offer pure
"zero interest"
borrowing
Low: capital-related
fees are often small
in absolute dollars
None: in most
cases, developers
typically bear the
upfront costs, and
many cities require
"growth pays for
growth" so that
costs are not
subsidized by the
general rate base
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6.2.2.3 Case Study Example: Flexibili
The Iowa SRF program has funded stormwater
projects, without affecting user fees, through the
Water Resource Restoration Sponsored Projects
program. A CWSRF project can carve out 1
percent of the interest that would have otherwise
been paid to the CWSRF program on its
infrastructure loan, using that money for a
nonpoint-source project. The SRF program allows
about $100,000 per $1 million CWSRF loan to be
used for water quality projects. Through this
overall interest rate reduction, the utility's
ratepayers do not pay any more than they would
have for just the wastewater improvements.
Stormwater projects including permeable
paving, bioswales, rain gardens, streambank
restoration and soil conservation projects on
agricultural lands have been funded. About $50 million for these projects have been approved for
funding.
6.2.3 Implications of Financial Capability Assessment Methodology
Financial capability assessments (FCAs) are distinct from various measures of household or individual
customer affordability (discussed below) in that an FCA relates to the ability of a community (or
permittee) to finance infrastructure investments. For a broad array of purposes, EPA has used a static,
two-phase methodology to conduct FCAs. Phase I involves calculation of a residential indicator (Rl),
which examines the average per household cost of services relative to a benchmark of 2 percent of
service-area-wide median household income (MHI).
Phase II involves the calculation of a financial capability index (FCI), a simple arithmetic average of scores
for six economic indicators:
* Bond rating
* Net debt as a percentage of full market property value
* MHI
* Local unemployment
* Property tax revenues as a percent of full market property value
* Property tax collection rate within a service area
ty in the Use of CWSRF
$1 rrmion CWSRF S' million loan wilh
lean sponsored p"cjec1
¦ Loan Costs
(interest and fees)
¦ Sponsored project
principal
~ Wastewater
principal
Figure 4. Graphic representing the current stormwater
management paradigm shift.
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A higher FCI score suggests relative economic strength; a lower FCI indicates weak economic conditions
and relatively lower financial capability. EPA's existing FCA guidance40 has been subject to extensive
review and critique for a variety of reasons that are particularly resonant for application to stormwater
related infrastructure financing. For example, the diversity of governance structures and financial
reporting protocols noted above makes even baseline evaluation of current funding complicated.
Financing stormwater infrastructure is often less straightforward than issuance of the revenue bonds
assumed to be available in EPA guidance. And profound complexities may be involved in assigning the
residential vs. non-residential flow contribution responsibilities required in EPA's matrix methodology.
Emerging concepts to address the limitations of EPA's current FCA methodology could also improve
evaluation of community financial capabilities to fund stormwater infrastructure (though the diversity of
governance configurations will continue to impose complexities). For FCAs, these concepts call for a
direct evaluation of a community's (or communities', in cases where stormwater services involve
multiple jurisdictions) financing capacity through cash-flow analyses. Current and potential new
methods for funding stormwater infrastructure would require explicit recognition (rather than being
subsumed within general government financial reporting). Projected tax or fee cost impacts on
individual households and non-residential entities may be calculated and gauged in relation to various
income metrics (e.g., median and lowest quintile, gross and disposable). Financial capabilities would be
assessed in terms of the community's ability to fund O&M expenses and capital spending given tenable
annual adjustments to stormwater-dedicated tax and fees. The pace and magnitude of these tax or fee
increases would be established by reference to new measures of household or individual customer
affordability as discussed below.
6.3 Custori
In the context of water and wastewater services, customers' hardships include various costs associated
with challenges in paying service bills, including even service interruptions. For stormwater services,
such customer affordability issues may manifest less explicitly or dramatically, but they nevertheless are
important considerations for stormwater finance policy development. And, as with FCA, both how
household affordability is measured and what constitutes burdensome levels of cost are being
reconsidered as concerns rise about water (i.e., drinking water, wastewater and stormwater)
affordability across all water-resource-related services.
Historically, EPA has measured water and wastewater service cost affordability largely in terms of how
estimates of annual household costs compared to MHI as reported by U.S. Census data. EPA's
historically used FCA matrix methodology may render a determination of "High Burden" for
communities where household costs are above 2 percent of MHI. Logically, though rarely done, the
same methodology can be applied to evaluation of stormwater service costs—especially (or at least
more easily) if such costs are explicitly calculable by reference to stormwater utility rates or fees rather
subsumed within general government funding sources. The historical underfunding of stormwater
management costs (even if recovered through separately established fees and charges) means that
stormwater management costs are unlikely to be deemed as currently imposing an undue burden using
40 U.S. EPA. 1997. Combined Sewer Overflows—Guidance for Financial Capability Assessment and Schedule
Development. EPA 832-B-97-004. February 1997. httpsi//www3,epa,gov/npdes/pubs/csofc,pdf
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historically applied metrics referencing MHI. In addition, the use of MHI as an affordability metric has
been widely criticized.41
Emerging concepts related to household water affordability measures (like those for FCAs) offer new
measures and methodologies for assessing water resource management costs beyond reference to MHI.
Cost as a percentage of lowest quintile income is advocated for its focus on the economically
disadvantaged; cost as a percentage of a measure of disposable incomes is advanced as a means to
gauge whether households will face undue substitutions of health care, food or other essential services.
Most importantly, these concepts call for inclusion of stormwater-management-related costs (incurred
via separate charges or through general taxes and fees) in the pantheon of claims imposed on
households for water resource management services.
41 AWWA. 2013. Affordability Assessment Tool for Federal Water Mandates.
https://www.awwa.0rg/Portals/O/AWWA/ETS/Resources/AffordabilitvAssessmentTool.pdf
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Appendix I: Municipal Financial Reporting and Asse
Manageme
In 1999, in a document known as Statement 34,42 the Governmental Accounting Standards Board paved
the way for a fairly large shift in the way public sector entities produce financial reports.
Statement 34 discussed infrastructure assets: "long-lived capital assets that are normally stationary in
nature and normally can be preserved for a significantly greater number of years than most capital
assets. Examples of infrastructure assets include roads, bridges, tunnels, drainage systems [emphasis
added], water and sewer systems, dams, and lighting systems. Buildings, except those that are an
ancillary part of a network of infrastructure assets, should not be considered infrastructure assets for
purposes of this statement."
In the excerpt below, Statement 34 encourages asset management:
[Depreciation expense] may be calculated for (a) a class of assets, (b) a network of assets,1 (c) a
subsystem of a network," or (d) individual assets...
Infrastructure assets that are part of a network or subsystem of a network1" (hereafter, eligible
infrastructure assets) are not required to be depreciated as long as two requirements are met. First,
the government manages the eligible infrastructure assets using an asset management system that
has the characteristics set forth below; second, the government documents that the eligible
infrastructure assets are being preserved approximately at (or above) a condition level established
and disclosed by the government. ¦ To meet the first requirement, the asset management system
should:
a. Have an up-to-date inventory of eligible infrastructure assets
b. Perform condition assessments' of the eligible infrastructure assets and summarize the results
using a measurement scale
c. Estimate each year the annual amount to maintain and preserve the eligible infrastructure assets
at the condition level established and disclosed by the government.
1 A network of assets is composed of all assets that provide a particular type of service for a
government. A network of infrastructure assets may be only one infrastructure asset that is
composed of many components. For example, a network of infrastructure assets may be a dam
composed of a concrete dam, a concrete spillway, and a series of locks. [This footnote
" A subsystem of a network of assets is composed of all assets that make up a similar portion or
segment of a network of assets. For example, all the roads of a government could be considered a
network of infrastructure assets. Interstate highways, state highways, and rural roads could each
be considered a subsystem of that network.
42 Governmental Accounting Standards Board. 1999. Basic Financial Statements—and Management's Discussion
and Analysis—for State and Local Governments.
http://www.gasb.org/cs/ContentServer?site=GASB&c=Document C&pagenaroe=GASB%2FDocuroent C%2FGASBD
ocumentPage&cid=1176160029121
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III If a government chooses not to depreciate a subsystem of infrastructure assets based on the
provisions of this paragraph, the characteristics of the asset management system required by this
paragraph and the documentary evidence required by paragraph 24 [which leaves documentation
to professional judgment] should be for that subsystem of infrastructure assets.
IV The condition level should be established and documented by administrative or executive policy, or
by legislative action.
v Condition assessments should be documented in such a manner that they can be replicated.
Replicable condition assessments are those that are based on sufficiently understandable and
complete measurement methods such that different measurers using the same methods would
reach substantially similar results. Condition assessments may be performed by the government
itself or by contract.
The Louisiana Division of Administration spoke for the vast majority of public sector entities across the
U.S. when it recommended in 1999 that the state "...choose the alternative, to depreciate the
capitalized infrastructure assets. We feel that this is the most cost-effective approach for reporting since
there would not be any significant burden involved in depreciating the infrastructure assets once they
have been identified and capitalized. The schedules of capitalized infrastructure assets would simply
include a column to compute the amount of annual depreciation. Under the modified approach, the
capitalization requirements are the same as under the depreciation alternative. However, the cost and
effort to follow the requirements of the modified approach would be significant and therefore more of a
burden than depreciating the infrastructure assets. In addition, with the uncertainty of state funding to
cover the additional costs of maintaining the state's infrastructure at specified condition levels as
prescribed in the modified approach, it is possible that the state would have to revert to the
depreciation alternative at some point in the future and face a qualification in the year we fail to
maintain at the designated level."
To date, less than 10 percent of the roughly 42,15844 units of government are estimated to be using the
modified approach. Municipal finance officials already face burdensome reporting and financial
statement preparation requirements that greatly inhibit their ability to produce independently audited
financial statements much before 120 to 180 days from the end of the previous fiscal year. Assuming
infrastructure assets have an expected useful life of 10 to 30 years, this completely ignores changes over
time in inflation, labor, building materials and technology and potentially introduces a very material gap
between "book value" and replacement cost. In a 2017 piece of research, RBC Capital Markets noted, "A
comprehensive inventory of public assets is a critical prerequisite to identifying opportunities to create
new value."45 Reliance instead on a depreciation-based, historical cost reckoning of infrastructure assets
43 Louisiana Division of Administration, n.d. "GASB Statement 34 Implementation Issues: Infrastructure
Reporting—Modified Approach vs. Depreciation."
http://www.doa.la.gov/osrap/librarv/gasb34/infrastructure%20reporting.pdf
44 Hogue, C. 2013. Government Organization Summary Report: 2012.
httpsi//www,census,gov/content/dam/Census/library/publications/2013/econ/gl2~cg~org,pdf. (This Census
summary identifies 38,910 general purpose governments. It excludes special and school districts but does include
3,248 special districts categorized as "drainage and flood control.")
45 RBC Capital Markets and HR&A Advisors. 2017. "Unlocking Value from Public Assets: Leveraging Private-Sector
Expertise to Generate New Public Benefits." p. 46.
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rather than an assessment that explicitly correlates asset condition to financial value not only introduces
public policy-making risk but also makes it more challenging to establish a baseline FCA.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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Appendix II: Case Studies
1. Washington, D.C. Stormwater Retention Credit Trading:
The U.S.'s First Stormwater Retention Trading Market in the Nation's Capital
2. Four San Francisco Bay Area Voter-Approved Fee Measures:
Stormwater Infrastructure User Fees
3. Stormwater Utility Goodlettsville, TN:
Watershed Protection through Stormwater Management
4. Los Angeles Parcel Tax Approved by Voters in 2018 (Measure W):
Stormwater Infrastructure User Fees
5. How Operation and Maintenance Costs Effect Resiliency in Coralville, Iowa:
Managing Flooding and Quality of Life
6. Stormwater Utility, Downers Grove, IL:
Flood Risk Reduction, Erosion Control, Water Quality Protection, and Drainage
Infrastructure Management
7. Watershed Protection in Austin, TX:
Flood Risk Reduction, Erosion Control, Water Quality Protection, and Drainage
Infrastructure Management
8. Stormwater Program Implementation in Atlanta, GA:
Water Quantity (Aging Infrastructure, Flood
Management, Drainage) Water Quality (Regulatory Compliance, TMDLs), Expanding
Expectations (public outreach, multi-use areas)
9. Washtenaw County, Michigan:
Summary Report of Stormwater Program Needs
10. City of Raleigh, North Carolina:
Basin Master Planning
11. City of Bellevue, WA Storm and Surface Water System Plan 2015:
WQ, Flood, Infrastructure, WIPs, Drainage
12. City of San Diego:
Watershed Asset Management Plan (2013)
13. Grand Rapids, Ml:
Flood Protection, Sediment Reduction, and Stormwater Quality Compliance in Water
Quantity (MS4 Permit and TMDLs Compliance)
14. Griffin, GA:
Stormwater Pipe Assessment: Water Quantity (Infrastructure, Drainage)
15. Ventura County, CA:
Flood Protection and Stormwater Quality Compliance
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
• • •
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Water Quantity (Flood Protection) and Water Quality (MS4 Permit and TMDLs
Compliance)
16. Stormwater Utility, Lawrence, KS:
Flood Risk Reduction, Erosion Control, Water Quality Protection, and Drainage
Infrastructure Management
17. Metropolitan Water Reclamation District of Greater Chicago:
Working hard to manage stormwater, clean wastewater and recover valuable resources,
18. Stormwater Environmental Utility, Sarasota, FL:
Control water quantity, enhance water quality, effectively manage stormwater
**«
City of Bellevue Storm and
Surface Water System Plan
2015
Metropolitan Water
Reclamation District of Greater
Chicago
Four San Francisco Bay Area
Voter-Approved Fee Measures
How Operation and
Maintenance Costs Effect
Resiliency in Corahrille, IA
Ventura County, CA
«**
•**
Los Angeles Parcel Tax
Approved by Voters i n 201S
{Measure W]
Grand Rapids, Ml
Washtenaw County,
Ml
Stormwater Utility
Downers Grove, IL
Stormwater Utility
Goodlettsville, TN
~I*
*4*
Washington, D.C. Stormwater
Retention Credft Trading
City of Raleigh, MC
dty of San Diego
Griffin, GA
Stormwater Program
Implementation in Atlanta, GA
Waterslwd Protection
in Austin, TX
Starrnwater Environmental Utility,
Sarasota, FL
Figure 5. Map depicting the location of various utilities included in the case studies.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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Washington, D.C.
Stormwater Retention
Credit Trading
The U.S.'s First Stormwater Retention
Trading Market in the Nation's Capital
In 2013 Washington, D.C. promulgated new
stormwater retention regulations for new development or substantial
improvement projects. Part of these new regulations was the introduction
of the Stormwater Retention Credit Trading market, which allows these
regulated projects to purchase up to 50% of their stormwater
management requirements offsite, in the form of Stormwater Retention
Credits (SRCs). This allows regulated properties to pursue more cost-
effective compliance methods and provides financial incentives for
properties to voluntarily install stormwater management practices. The
underlying regulation and the new market are designed to help the
District meet its MS4 permit requirements and 2025 TMDL goals in a cost-
effective way, using private investment and private property.
Challenges
County or Municipality
Washington, D.C.
Population
702,445
Annual Rainfall
40.78 inches
Land Area
68.34 square miles
Poverty Level
17.4%
Total Identified Need
$10 billion?
Annual Capital Budget
$10 million?
Annual O&M Budget
N/A
Polluted stormwater runoff is a primary threat to water quality
nationwide and is one of the biggest threats to the Chesapeake Bay. The
Chesapeake Bay is the largest and most productive estuary in North
America. Economists value fishing and hunting, tourism, and shipping
activities along with increased property values in the Bay at over $1 trillion
per year. Stormwater runoff represents the second largest source of
nutrient and sediment pollution and is the only sector in the Chesapeake
watershed growing in its impact, due to population growth and land
development. At the same time, many cities are struggling to finance the water infrastructure
improvements needed to prevent stormwater runoff.
Washington, D.C. is 43% impervious and is a major source of this stormwater runoff, which impacts the
local Anacostia River, Potomac River and Rock Creek as the water flows out to the Chesapeake Bay.
However, getting retrofits installed to serve the 43% of D.C.'s land area that is impervious is a difficult
challenge. The majority of this impervious surface achieves little or no retention, is not required to
retrofit, and does not have financing available to support a retrofit.
Further, Washington, D.C.'s Department of Energy and the Environment (DOEE) estimates that to meet
its permit requirements and achieve its water goals, $10 billion in investment is necessary. However,
DOEE only collects ~$10 million in revenue per year.
Solution
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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DCs Department of Energy and the Environment (DOEE) has developed a first-of-its-kind in the country
stormwater retention credit trading program for new development and major renovations. This
program requires new projects to retain the stormwater generated from their development. However,
to help land-constrained property owners meet these requirements, the city instituted a credit market
for stormwater, which allows these regulated projects to purchase up to 50% of their stormwater
management requirements offsite, in the form of Stormwater Retention Credits (SRCs). The SRC market
was designed with two goals in mind: i) provide a cost-effective solution for developers to meet their
retention requirements, while achieving significant co-benefits for the city; and ii) allow the District to
meet its own green infrastructure goals at a lower cost than it could using only public land and financing.
Currently, SRCs are trading at close to half the cost of public delivery of equivalent infrastructure and it
is estimated that the 2013 rule and subsequent SRC activity will increase spending on stormwater
mitigation by lOx historic public investment. Further, DOEE recently introduced a public purchase
program, Price Lock, whereby the District purchases projects at a market rate that best meet DOEE's
clean water goals. These public purchases reduce the cost of compliance for the District and help bolster
development of credit supply in parts of the District where stormwater mitigation is most needed.
Mitigating runoff at the cheapest cost possible is a major hurdle for jurisdictions in the Bay and around
the country. Washington, DC is using the SRC market to prove that market forces can accelerate the
deployment of green infrastructure through private investment and in doing so, obviate the need for
future public gray infrastructure spending to reduce stormwater runoff.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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Stormwater Utility
Goodlettsville, TN
Watershed Protection through
Stormwater Management
Overview
GOODLETTSVILLE
The City of Goodlettsville, TN is located in the North Central area of
middle Tennessee. In 2013, the City completed a Stormwater
Management Master Plan identifying the city's drainage basins and
recommended the enactment of a stormwater utility fee as a
dedicated funding source.
History
The Stormwater Utility Ordinance, implemented in 2013, is organized
into three main sections: Capital Improvements, Capital Maintenance,
and Engineering review. The utility is responsible for all activities
related to the operation and maintenance of the stormwater system,
including master planning, the capital improvement program, and
inspections.
As one of the first stormwater utilities created in middle Tennessee,
the City of Goodlettsville has been a leader among local governments
in developing such a program. The City of Goodlettsville assesses its
residential customers on Equivalent Residential Units (ERU's) which are
based on the effective impervious area of the average single-family
parcel of $3.67 per month. The assessment of Commercial and
Industrial properties are based on the actual impervious surface with
on ERU equivalent to 2900 sq. ft. at $5.50 ea. per month.
County or Municipality
City of Goodlettsville, Tn.
Population
16,859 (2018)
Annual Rainfall
62.3 inches
Land Area
14,1 sq. mi.
Poverty Level
18.1%
Total Identified Need
$1,250,000.00
Annual Capital Budget
$400,000.00
Annual O&M Budget
$850,000.00
Flooding Level of Service is intended to protect habitable structures up to the 100-year, 24-hour rain
event. Water quality requirements from regulatory ordinances include all new development or re-
development of greater than one acre, or less than one acre if part of a larger common plan.
Capital Needs
To-date, the City has collected $3,200,000 in stormwater utility fees and has spent $1,400,000.00 in
stormwater flood improvements, operations and maintenance throughout the city. Since
implementation of the program, a rate increase has not occurred and the program has not taken out
loans to fund projects. Future projects include Drainage Basin Area Study, Box Culvert Replacement and
Upgrades, Major Roadway Drainage Study, and completion of a Flood Mitigation Program
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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How Operation and
Maintenance Costs Effect
Resiliency in Coralville,
Iowa
Managing Flooding and Quality of Life
The City of Coralville funds the operation and
maintenance of stormwater infrastructure through a
local stormwater utility fee, property taxes, and
federal/state road use tax.
Operation and maintenance activities related to local
water quality include compliance of the City's MS4
permit, which consists of staff time, training, and maintenance of water
quality practices installed as part of public infrastructure projects
(roadway projects); street sweeping; and catch basin cleaning.
Operation and maintenance activities related to flood control and
water quantity include staff time and training, maintenance of the
flood protection system (pump stations, permanent flood
walls/barriers, earthen berms, and detention basins), and maintenance
of the storm sewer system (catch basins, pipes, and outfalls).
In the last 25 years, Coralville has experienced two major flooding
events on the Iowa River. In 1993, a flood described as a "100 year
event" devastated homes and businesses, and caused millions of
dollars in damage. Of the businesses affected, 20% chose to not
rebuild. In 2008, the Iowa River flooded again. This time, it was a 500
year event with costs totaling $21 million for commercial properties, $4
million for residential properties, and $7 million in damages to public
infrastructure. After the 2008 flood, 40% of the businesses chose to
not rebuild.
County or Municipality
Coralville, Iowa
Population
21,664
Annual Rainfall
37"
Land Area
12 Sq miles
Poverty Level
14% of citizens are
considered impoverished
Total Identified Need
3 Million
Annual Capital Budget
$0
Following the 2008 flood, Coralville was awarded $65 million in federal
and state grants to create a flood control system, which the City implemented. This permanent flood
control system is essential to protecting our community. Maintaining the floodwali and stormwater
pump stations accounts for 40% of the total stormwater budget. The remaining budget covers staff and
all other operations and maintenance-related activities mentioned above, leaving a deficiency in
maintenance objectives and very little funding for capital improvement projects. One of the largest
deficits can be seen in the maintenance of our regional detention ponds. These ponds protect residents
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
• • •
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from localized flooding events driven by heavy rainfall. This maintenance cost is estimated at 3 million
now with an annual expense of $50,000 in continuing unmet need.
One of the largest complaints Coralville receives from residents is related to localize flooding concerns
on their property. Residents expect their municipality to protect them from flooding, whether it is from
the Iowa River or stormwater in the roadway or behind their home. Maintaining regional detention
ponds and the local storm sewer system is essential for reducing the risk of localized flooding. The
maintenance of local detention ponds is not being completed due the deficit in the stormwater budget.
Over the past five years, the Iowa Flood Center has observed a 40% increase in the precipitation
amounts of large rain events. We see that data in action. We are experiencing an increased need to
protect our community during these heavy rain events. We project that the ongoing maintenance
requirements of our system will increase as our storm events become larger and more destructive.
None of our stormwater systems are large enough to carry the rain events we have been experiencing.
The oldest sections of town, where the storm systems tend to be the most undersized also coincide with
our most impoverished and vulnerable populations.
Without additional funding to support the operation and maintenance cost of our stormwater system,
we will continue to fall further behind. As storm events increase in size, these systems will be essential
to protecting the quality of life of our residents.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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Stormwater Utility,
Downers Grove, IL
Flood Risk Reduction, Erosion Control,
Water Quality Protection, and Drainage
Infrastructure Management
Overview
The Village of Downers Grove, IL is located 22 miles
west of Chicago. In 2006, the Village adopted a Stormwater
Master Plan that provided information about the existing
stormwater problems in the Village, the condition of the
stormwater system, the adequacy of system components, and
estimated costs for necessary maintenance, capital improvements
and regulatory requirements at the time of publication,
A Stormwater Utility Fee was established in 2012 to provide a
dedicated revenue for the identified stormwater management
needs.
History
This 2006 Master Plan document provided the Village with
information for establishing strategies for future infrastructure
management, identifying preliminary budgetary needs, and
identifying alternatives for financing an adequate stormwater
program.
Prior to the Stormwater Utility, operating costs for the
stormwater system were funded primarily through property
taxes. Shifting the source of funding to a utility/fee-based system
resulted in a reduction in the property tax levy by approximately
$2.48 million, beginning with the 2012 levy.
The Stormwater Utility Fee model represents an equitable
method to collect revenue from those properties that place a
demand on the system. Revenue is generated by charging all
property owners a monthly stormwater fee, based on the
property's impact to the stormwater system. The Village has
created a plan that increases revenues over a 15-year period,
allowing the Village to move from the current level of service to
the recommended level within that time frame.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
• • •
87
County or Municipality
Village of Downers Grove, Illinois
Population
49,649
Annual Rainfall
38" (Illinois)
Land Area
• Approximately 7,000
drainage structures
• 315 stormwater detention
facilities
• 130 miles of storm sewer
pipes
• 12 miles of streams
• 140 miles of roadway
ditches
• 47,000 feet of culverts.
Poverty Level
5.39%
Total Identified Need
$340M
Annual Capital Budget
FY19 Budget includes $7.08M for
stormwater capital projects.
Annual O&M Budget
$2M
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The plan calls for annual increases in the stormwater utility fee of approximately 8.5% per year, which
would increase the annual revenue available for stormwater management fees from the level of $4.6
million to about $11.4 million in 2028.
Capital Needs & Funding Sources
The 2007 Watershed Infrastructure Improvement Plan identified estimated cost of $340 million for
stormwater management projects. The more recent 2014 Stormwater Project Analysis identified 17
non-floodplain and 3 floodplain projects to provide 95% protection for the 21 areas throughout the
Village that were identified as significantly impacted by the April 2013 floods. The estimated cost to
complete the 17 non-floodplain projects is $11.6M and they are planned to be completed in 2020. The
annual cost for stormwater maintenance activities are $2.0M each year. However, it would cost about
$4 million per year to perform the recommended annual maintenance activities.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed
approved by the chartered EFAB, and does not represent EPA policy.
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Watershed Protection in
Austin, TX
Flood Risk Reduction, Erosion Control,
Water Quality Protection, and Drainage
Infrastructure Management
Overview
The mission of the City of Austin's Watershed Protection
Department (WPD) is to protect the lives, property, and
environment of the community by reducing the impacts of
flooding, erosion, and water pollution. The department provides
services for the City of Austin and its extraterritorial jurisdiction
through a combination of capital improvement projects,
operating programs, and regulations. The department also serves
as the City's drainage utility—it is responsible for the operation,
maintenance, renewal, and upgrade of the public stormwater
infrastructure system. This includes the inspection and
maintenance of assets that convey, store, and treat stormwater
runoff while complying with state and federal regulatory
requirements, such as the Municipal Separate Storm Sewer
System (MS4) permit issued by the Texas Commission on
Environmental Quality (TCEQ).
Over the years the City of Austin has received numerous awards
for its watershed protection and management programs. In
2017, the Watershed Protection Department was the highest
scoring Phase I MS4 program nationally among those submitting
nominations for the annual Water Environment Federation /
USEP MS4 awards program. Austin was also received gold-level
recognition that year for innovation and for program
management.
History
For more than three decades, WPD has been recognized as a
national leader in watershed protection. The two most important
events that helped shape the City's watershed protection
program were uncontrolled development in the late 1970s and
the Memorial Day Flood of 1981 In the late 1970s, sediment
from widespread construction visibly entered Lake Austin, the
City's water supply, and Barton Creek, a beloved community
City of Austin, Texas
Watershed Protection
Department
Population (Jan 2019)
981,035
Average Annual Rainfall
34 inches
Estimated Rainfall in 24-
hour Storm Event
25-year: Up to 9 inches
100-year: Up to 13+ inches
Land Area
326 sq. mi.
Poverty Level (Jan 2018, U.S.
Census)
15.4%
Total Identified Capital Need
(10-Year Planning Estimate)
$2 billion
Annual Capital Budget
(FY19)
$35 million annual transfer +
developer mitigation fees +
bonds
Annual O&M Budget (FY19)
$104 million
Workforce (FY19)
349 full time employees
26 temporary employees
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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swimming and hiking area. Public concern led to calls for improved environmental protection through
water quality and erosion controls for development. Around the same time, the Memorial Day Flood of
1981 underscored Austin's geographic location in what is known as America's "Flash Flood Alley"—an
area of unusually intense flooding events. In response to the storm's devastating effects and loss of life,
the City implemented a Drainage Charge in 1982 to provide funding for an expanded stormwater
management program. In 1991, the City established a Drainage Utility to oversee and directly fund its
stormwater management programs. The Watershed Protection Department (WPD) was created in 1996
through the merging of the flood and erosion programs in Public Works with the water quality
protection programs of the Environmental and Conservation Services Department.
Capital Needs and Funding Sources
To fund its capital projects, WPD utilizes a combination of funding sources, including general obligation
bonds, drainage fees, payment-in-lieu developer mitigation programs, and Certificates of Obligation
from tax increment financing.
The department has identified more than $2 billion in capital needs to address the City's most severe
flood, erosion, water quality, and infrastructure maintenance needs over the next 10 years. With an
estimated capital budget of approximately $700 million over that same timeframe, the department
utilizes principles defined in the department's Watershed Protection Master Plan, Strategic Asset
Management Plan, and City of Austin Long-Range CIP Strategic Plan to prioritize solution
implementation within its budget.
The department continues to evaluate and update its best practices for stormwater management and
CIP prioritization by incorporating community priorities, policy decisions, and the latest technical data,
such as the Atlas 14 historic rainfall study.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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EFAB Stormwater Case Studies
Stormwater Program Implementation in
Atlanta, GA
Water Quantity (Aging Infrastructure, Flood
Management, Drainage), Water Quality (Regulatory
Compliance, TMDLs), Expanding Expectations (public
outreach, multi-use areas)
The City of Atlanta is a regional center located in the
Southeastern United States. Situated in the headwaters of
two river basins, the City provides drinking water,
wastewater, and watershed management services to nearly
half a million people within the City's jurisdictional
boundaries and some areas outside the boundaries. The
Department of Watershed Management (DWM) is
responsible for the NPDES MS4 permit in addition to state
and regional requirements. DWM stormwater functions
include watershed improvement planning, drainage
improvements, asset management, water quality
improvements, regulatory compliance, and public education
and outreach. The City has a combined sewer system (CSO),
which has resulted in increased emphasis on stormwater
infiltration practices to reduce the stormwater runoff load
to the CSO.
Stormwater Program Funding
County or Municipality
City of Atlanta, GA
Population
498,044 (2018 US)
Average Annual Rainfall
49.71 inches (NOAA)
Land Area
136.7 sq. mi.
Poverty Level
22.4% (U.S. Census)
Total Identified Needs
FTEs -122
Annual Operating Costs - $12 million
Annual Capital Costs - $18 million
Annual Total Costs - $30 million
Current Capital and O&M Budget
FTEs - 60.5
Annual Operating Costs - $6.6 million
Annual Capital Costs - $12.5 million
Annual Total Costs - $19 million
The City of Atlanta does not have a dedicated funding
source for stormwater management activities and
stormwater management is currently limited to meeting
regulatory mandates and addressing emergency repairs.
Much of the existing stormwater drainage infrastructure
within the City is nearing the expected lifespan and will
need to be repaired or replaced. In addition, many
customer requests for stormwater infrastructure improvements have not been addressed due to the
lack of adequate funding.
Increasing stormwater-related regulatory requirements, changing weather patterns, more frequent
nuisance flooding issues, and aging infrastructure needs have prompted the DWM to consider a
dedicated funding source and develop annual operating and capital funding needs. An evaluation of
future resource needs identified 122 full time equivalent (FTE) employees, $12 million in annual
operating costs, and $18 million in annual capital expenditures to meet stormwater program
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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requirements and level of service. This is an approximately 50% increase over current resource and
funding levels.
Extent of Service Area
Stormwater services will be provided for the following areas:
i Municipally owned rights of way
i Municipally owned drainage easements
§ Municipally owned ponds and structural stormwater control facilities
§ Rivers and streams on municipally owned property or the ROW
The City's inventory within municipally owned property or within public Right of Way includes an
estimated 150 miles of stormwater pipe; 9,500 catch basins; 10,000 headwall, manholes, outfalls,
culverts, and other miscellaneous stormwater structures. A significant portion of this stormwater
infrastructure is not maintained on a routine basis; is reaching the normal engineering lifespan and is in
need of repair or replacement. Stormwater facilities on private property are excluded from the City's
Extent of Service.
The City of Atlanta is a leader in implementing green infrastructure programs and developing creative
funding solutions such as MOST, grants, and an Environmental Impact Bond. However, meeting the
identified funding needs gap will take additional creative planning, coordination, and communication
with local and national stakeholders.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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Washtenaw County Michigan
Summary Report of Stormwater Program Needs
We have completed Master Plans for some of our larger sub-
systems (8 of some 550). We have an asset management plan
(AMP), but no predictable means of planning capital work due
our organizational structure as a special assessment agency by
statute. Our current goal is to increase annual spending on
minor, pro-active preventative maintenance where we have
authority (we can spend $0.97 per foot of drain without a
petition). We are working to raise awareness of capital needs to
achieve a goal of petitions that result in $5-$10M of capital
projects annually. Information from our AMP suggests that
we could proceed for 10-15 years in this fashion (working on
whatever people are willing to ask us to work on at their
expense) without compromising any logical sequence of
capital improvements.
Our system replacement value is estimated at $430M in
today's dollars. Our data source is our Asset Management
Plan which indicates that about 15% of our system is in
immediate need of replacement due to complete lack of
function. We are currently seeking to raise awareness of
these and other poorly performing sections of infrastructure
with those who would pay. Our only mechanism for capital
project initiation is by petition, so long-range planning is a
challenge. Because we can receive a petition from either a
group of citizens or as a Resolution from a municipal agency,
we have started a process of seeking regular approval of
major maintenance on an annual basis with municipalities
within our jurisdiction. We have currently done this with 6 of
the 28 municipalities and hope to use this process for capital
work also. We have currently done a 5-year plan with each.
The idea is to annually have an approved one-year budget
and acceptance of a rolling 5-year budget forecast - for most
of our municipalities.
County or Municipality
Washtenaw County, Ml
Population
360,000
Annual Rainfall
35 inches
Land Area
446 square miles
Poverty Level
14.5% population below poverty level
Total Identified Need
$64.5 million
Annual Capital Budget
Varies by petitions received
Annual O&M Budget
$4.1 million
Due to having systems that pre-date current water quantity management design standards, all of our
capital work focuses on improving water quality while striving to maintain the quantity management of
the original system. In some cases, the water quality measures (such as extended storage) may provide
an ancillary quantity benefit in smaller storms (85th percentile or smaller, so first flush to one-year
storm sizes may have quantity benefit).
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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The County does include MS4 permittees, but not the entire system as our service area includes
urbanized and rural census tracts. Generally, our enclosed pipes in our urbanized area are designated
MS4s and open ditches are not. Our biggest problems are in the urbanized areas but those are generally
not available for federal or state funding for improvements, because we are supposed to be responsible
for those through the unfunded mandate of MS4. (Incidentally, the Ml State Supreme Court ruled that
MS4 regulations were NOT an unfunded mandate, stating that [paraphrased] "municipalities have never
been mandated to provide drainage systems, so MS4 regulations only apply to those communities who
have chosen to have stormwater systems.").
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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City of Raleigh, North
Carolina
Basin Master Planning
We have developed a preliminary estimate of citywide needs
related to stream stabilization/restoration, which has not
been included in past studies. The preliminary estimate for
citywide stream stabilization/restoration needs is approximately $120 million, which is beyond stream-
related projects identified in the basin studies. Within the past several years, the City's Stormwater
Program has also expanded its scope and assumed responsibility for City owned/operated Stormwater
Control Measures (SCMs) and Dams. Approximately $10 million in capital repair needs has been
identified for dams while assessment continues for both SCMs and Dams.
Annual O&M Budget
$14.3 million
The City of Raleigh has performed and completed a number
of past drainage basin and watershed-based studies.
Approximately % of the city area has been covered by basin
studies, although some of these were completed more than
twenty years ago. The studies have looked primarily at
infrastructure hydraulic capacity and flood hazard reduction
needs and projects. Some studies have also reviewed water
quality-related needs with projects identified including lake
restoration/retrofit and stream stabilization/restoration
opportunities along with other water quality-oriented
projects. Recently (earlier in 2019) the City completed the
first phase of a multi-phase integrated watershed master
planning project. As part of this recent work, the City asked
its consultant to identify and summarize stormwater projects
identified from past basin studies but not yet constructed. In
this context, the total of stormwater projects identified from
past basin studies is approximately $280 million, escalated to
2019 dollars.
In addition to this, the City has approximately $60 million of
projects that are assumed to be beyond what has been
identified from past studies. The current CIP plan includes
master planning, water quality retrofits, flood hazard
reduction, lake-related projects, stream restoration, and
neighborhood and street drainage system repair projects.
County or Municipality
Raleigh, NC
Population
458,862
Annual Rainfall
46 inches
Land Area
145.98 square miles
Poverty Level
16.8% households under $25K income
Total Identified Need
$470 million
Annual Capital Budget
$11.1 million
In summary based upon the above, a preliminary estimate of capital improvement program needs for
the City's Stormwater Management Program is approximately $470 million.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
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approved by the chartered EFAB, and does not represent EPA policy.
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The planning period for this portfolio is assumed as 20 to 30 years, although implementation will be a
function of future stormwater program revenues that may be available over time. (Note this
preliminary planning level CIP total does not include the estimated annual needs for MS4 operation,
maintenance, and MS4 repairs and rehab from a developing asset management perspective. The annual
needs related to asset management are included within the response to Question #3.)
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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City of Bellevue, WA Storm and Surface Water
System Plan 2015
WQ, Flood, Infrastructure, WIPs, Drainage
The City's Storm and Surface Water plan evaluates the
operational management of the Utility, providing a
"roadmap" for future planning. It is a tool to help the
City meet federal, state, and regional regulations. Key
focus areas include: control damage from storms (100
year, 24 hour storm event), protect surface water quality,
support fish and wildlife habitat and protect the
environment.
Primary challenges include aging infrastructure, reduced
forest cover, global climate change and a new class of
pollutants has emerged as a potential threat to aquatic
and human health over the last decade. Pharmaceuticals
and endocrine disrupters (found in some pesticides or
other products applied to the landscape) are increasingly
being detected in receiving water bodies. Stormwater
has been identified by the Puget Sound Partnership as a
primary pressure impacting the health of Puget Sound.
Bellevue does not have widespread flooding problems.
The City is in 100% compliance with Phase II NPDES
Municipal Permit
County or Municipality
City of Bellevue, WA
Population
147,599 (recent US census estimates)
Annual Rainfall
42 inches of rain, on average
Land Area
86.66 (33.46 square miles)
Poverty Level
7.37% of overall population. Median
household income 2019 $105,000
Total Identified Need
$275 million next 20-years
Annual Capital Budget
$13.5 million annual rate funded capital
from operations and asset replacement
account funding (average $11.5 million
2016 - 2019). No debt funding
Annual O&M Budget
$13.4 million (average $12.5 2016 - 2019)
Rate Structure: Accounts are billed at different rates
depending on the intensity of development
(undeveloped, lightly developed (20%), moderately
developed (40%), heavily developed (70%), very heavily
developed (over 70%) and wetlands). 2019 rates include
billing charge $5.88, plus charge per 2,000 square feet depending on intensity of development noted
previously, $0 wetlands, $.098 undeveloped, $7.08 lightly developed, $8.84 moderately developed,
$13.26 heavily developed and $17.65 very heavily developed.
Bellevue has a successful and established asset management program.
The Renewal and Replacement (R&R) reserves were established by the City Council in 1995 to better
position the City for the future by planning for the inevitable replacement of the utility system
The Utilities Department has assets with a replacement value of over $3.5 billion in 2010 dollars, and
about half of this aging infrastructure is past mid-life.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
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approved by the chartered EFAB, and does not represent EPA policy.
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Accumulating R&R reserves in a measured way to pay for the proactive replacement of aging systems
before they fail. Managing reserves that fund the replacement of that infrastructure is critical to
financial sustainability. R&R reserves ensure that the Utilities Department is financially prepared to
respond to emergency events. Use of R&R reserves is governed by state law and the Utilities financial
policies (established by City Council resolution in 1995; see Chapter 4 Policies).
R&R needs are projected using asset management data to determine the timing and estimated cost of
replacing systems over time. Annual revenues set aside for infrastructure replacement are based on
projected replacement cash flow needs over a 75-year forecast period less projected interest earnings.
In 2015, the storm and surface water repair and replacement fund had a balance of $43.8 million and
projected to increase to $70 million by 2044 (Figure 6).
Recommendations include:
Continue investing in the Flood Control Capital Program to reduce or eliminate local flooding caused by
insufficient public drainage system capacity. Continue to use King County Flood Control Zone District
Sub-Regional Opportunity funds. Invest in cost-effective water quality projects. Consider emerging
technologies and techniques that improve water quality for pilot projects. Continue to invest in the Fish
Passage Improvement Program to remove fish passage barriers created by impassable culverts, debris
jams, or accumulated sediment, which opens spawning and rearing habitat for salmon populations.
Continue to invest in the Stream Channel Modification Program to construct habitat improvements on
stream channels. Invest in the Stream Restoration for Mobility and Infrastructure. Continue to invest in
the Stormwater System Conveyance Infrastructure Rehabilitation Program to rehabilitate or replace
defective storm drainage pipelines and ditches identified in the condition assessment program.
Continue to invest in Minor (Small) Storm and Surface Water Capital Improvement Projects, to resolve
deficiencies, improve efficiencies, or resolve maintenance problems. When possible, complete in
conjunction with other Bellevue programs such as the transportation overlay program.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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Description
20-Year Total % of Total
Minor Storm & Surface Water Capital Imp. Projects
$
2,052,000
0.75%
Storm WaterSystem Conveyance Infrastructure Rehabilitation
$
10,457,000
3.80%
Replace Coal Creek Pkwy. Culvert at Coal Creek
$
26,000
0.01%
Replace NE 8th St Culvert at Kelsey Creek
$
136,000
0.05%
Stormwater Pipeline Video Inspection Enhancement
$
246,000
0.09%
Long-Term R&R- Mains
$
97,492,738
35.41%
Long-Term R&R - Facilities
$
348,166
0.13%
Long-Term R&R - Additional Costs
$
6,852,242
2.49%
Long-Term R&R- Contingency (40% of Aging Infrastructure)
$
39,136,362
14.21%
Fish Passage Improvement Program
$
2,533,000
0.92%
Stream Channel Modification Program
$
3,642,000
1.32%
Flood Control Program
$
5,790,000
2.10%
Stream Restoration for Mobility & Infrastructure Initiative
$
108,000
0.04%
Lower Coal Creek Flood Hazard Reduction
$
6,128,000
2.23%
Storm Water Quality Retrofit in Kelsey Creek
$
342,000
0.12%
Long-Term Environmental Preservation Projects
$
36,752,063
13.35%
Long-Term Mobility & Infrastructure Projects
$
63,295,219
22.99%
Long-Term Mandate Compliance Projects
$
-
0.00%
Total
$
275,336,791
100.00%
Figure 6. 2015 stormwater-related budget for the City ofBellevue, WA.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
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approved by the chartered EFAB, and does not represent EPA policy.
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City of San Diego
Watershed Asset Management Plan (2013)
In order to anticipate and justify current and projected
costs of complying with federal, state, and local
stormwater regulations, the City of San Diego developed
an integrated Watershed Asset Management Plan
("WAMP") for its stormwater management system. The
WAMP was finalized in 2013 and aims to lay the
groundwork for meeting regulatory requirements by
'annualizing' long-term compliance needs as well as documenting
and communicating expectations of citizens regarding functions of
the storm drain system and the quality of water and related
services. The first element of the WAMP assesses the current
inventory, costs, and condition of the City's stormwater system.
Assets are categorized as "hard," "natural," or "soft" and valuated
accordingly. After assessing the current state of City-managed
assets, the WAMP goes on to quantify a long-range forecast of
funding necessary to maintain a baseline level of service. The
projections are calculated using a custom-built database which
balances refurbishment and replacement costs to keep assets
functionally above a minimum acceptable threshold. The result of
this forecasting projected a 100 year need of nearly $20 billion (in
2013 dollars); equating to about $200 million per year, accounting
for regulatory compliance, capital, and O&M costs. Lastly, the plan
articulates various potential funding sources and scenarios for
achieving targeted levels of service. Scenarios range from current
budget to full funding attainment and lay out resulting backlog of
needed infrastructure upgrades that would result from each
scenario. Developing a WAMP is an iterative process requiring
continual input from stakeholders, new or improved data, and
updates to fiscal modelling efforts as awareness of costs becomes
more sophisticated, particularly in accounting for effects of climate
change. Currently, the City is undertaking a comprehensive update of its WAMP in order to reflect new
regulations, assets, and cost estimates. The process of developing a WAMP can also serve to inform the
regulatory process. In particular, an asset management perspective in context of a TMDL could
substantiate reasonable compliance schedules for water quality attainment. In the context of
stormwater permitting, an asset management plan could be used as a compliance mechanism
alternative to meeting water quality-based limitations.
1 E-l Population Estimates. Demographics. California Department of Finance website.
2 Western Regional Climate Center website
3 2018 Census Gazetteer Files-Places. United States Census Bureau website
4 United States Census Bureau website-QuickFacts City of San Diego.
City of San Diego Watersheds
County or Municipality
San Diego, California
Population
1,419,845 million-
Annual Rainfall
10.13 inches2
Land Area
325 square miles3
Poverty Level
14.5%4
Total Identified Need
$3,128,424,9385 (FY2019-35)
Annual Capital Budget
$2,666,667 (FY2020)
Annual O&M Budget
$51,967,670 (FY 2020)
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
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approved by the chartered EFAB, and does not represent EPA policy.
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Grand Rapids, Ml
Flood Protection, Sediment Reduction, and Stormwater Quality Compliance
Water Quantity (MS4 Permit and TMDLs Compliance)
The Environmental Services Division (ESD) is responsible for managing stormwater within the City of
Grand Rapids. The primary goals of the City's
stormwater program are to reduce the impacts of
flooding and erosion (water quantity) and to improve
water quality in local rivers, lakes, and streams. This
includes complying with the City's MS4 permit and
TMDL requirements for E. coli and biota. To help meet
these goals, the City developed a stormwater master
plan that incorporates a 20-year asset management
plan and capital improvement plan (CIP), as well as
other stormwater- and sustainability-related City
initiatives.
County or Municipality
City of Grand Rapids Environmental Services
Division, Ml
Population
198,829 (2017)
Annual Rainfall
37 inches
Land Area
45.3 square miles
The City's asset management plan identifies four level
of service scenarios for stormwater management,
including three new levels of service (A, B, and C) and
the existing level of service. The new levels of service
were designed to meet regulatory requirements, goals
for infrastructure renewal and replacement, and
operations and maintenance. In addition, each
scenario allocates a percentage of capital investment
to green infrastructure practices. Under the City's plan,
level of service A represents the highest level of
service, while B and C result in subsequently lower
service requirements.
Poverty Level
15.8'-'.. (persons in poverty, 2017 1-year
estimate)
MHI $48,521
Annual Revenue
$599,986 (FY 2018) - from licenses and
permits, state grants, charges for services
Annual Budget*
$3,867,433
Total Identified Need
$6,509,567 per year (through 2033)
Based on an evaluation of existing stormwater assets
and a comprehensive risk assessment, the City developed a 20-year CIP for level of service B, which
represents the mid-range level of service from the asset management plan. The City estimated that total
annual funding requirements for this desired level of service would amount to $14.7 million per year (for
20-years). However, due to funding constraints, the City is now aiming to achieve the levels of service
associated with scenario C of the asset management plan, which will require $10.4 million in annual
expenditures. This compares to annual funding requirements for maintaining existing levels of service of
$3.6 million.
In Michigan, it is difficult to establish a stormwater utility because of legal circumstances. Thus, the
City's stormwater program is funded from the City General Fund, as well as the Local and Major Streets,
Refuse, and Vital Streets Funds. The Vital Streets program, which includes green infrastructure and other
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approved by the chartered EFAB, and does not represent EPA policy.
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stormwater components as part of comprehensive street improvement projects, has been funded for
the last 15-years through a voter-approved income tax.
In FY 2018 the City's budget for stormwater management and maintenance was $2.7 million, while the
capital budget amounted to $1.2 million (including approximately $674,00 from the General Fund and
$536,000 from Vital Streets). The total $3.87 million budget is below the funding needed to meet the
City's level of service goals. While the City continues to make progress and has been recognized
nationally for its excellence in service and innovation,46 bridging this funding gap will require additional
sources of funds and/or a longer timeline for achieving the City's goals.
46 In 2017, the City of Grand Rapids received a gold recognition in program management award through the Water
Environment Federations' National MS4 and Green Infrastructure Awards Program.
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This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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Griffin, GA
Stormwater Pipe Assessment: Water
Quantity (Infrastructure, Drainage)
The City of Griffin lies on the continental divide with
watersheds draining to two different basins. Located about
an hour south of Atlanta, this small MS4 Phase 2
community created the first stormwater utility in the state
of Georgia and has been on the forefront of
stormwater management for many years.
The City prepared a condition and risk assessment of
all stormwater infrastructure within the City
boundaries in 2016. The assessment included 6,792
pipes and associated infrastructure. Condition
assessment was developed using a standardized
approach and defined criteria. Only infrastructure in
the poor category were considered for replacement
estimates as a capital expense. Not included in the
estimate is on-going maintenance expense associated
with clearing pipes blocked with debris. Up to 30% of
the stormwater infrastructure is considered blocked in
some areas, reducing the effectiveness of the
conveyance system and increasing maintenance costs.
Risk assessment criteria included FEMA floodzones,
proximity to buildings, and road classification.
Infrastructure determined to be high risk and poor
condition will be prioritized for maintenance and/or
replacement.
County or Municipality
Griffin, GA
Population
22,878 (US Census 2018)
Annual Rainfall
49.7 inches (US Climate Data)
Land Area
square miles (US Census 2018)
Poverty Level
31.4% (US Census 2018)
Total Identified Need
$23 million
Annual Capital Budget
$443,000
Annual O&M Budget
N/A
As part of this study, a replacement cost estimate was
developed based on comparable construction costs
and included factors such as pipe material, pipe diameters, and replacement method. Only for
stormwater infrastructure determined to be in poor condition, the replacement cost is estimated to be
$23 million.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
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approved by the chartered EFAB, and does not represent EPA policy.
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Ventura County, CA
Flood Protection and Stormwater Quality
Compliance
Water Quantity (Flood Protection) and
Water Quality (MS4 Permit and TMDLs
Compliance)
The Ventura County Public Works Agency's Watershed
Protection District (VC WPD) is the regional flood protection
service provider in Ventura County in addition to local
systems in ten incorporated Cities of Camarillo, Fillmore,
Moorpark, Ojai, Oxnard, Port Hueneme, Ventura, Santa
Paula, Simi Valley and Thousand Oaks. VC WPD is also
leading collaborative efforts by the County of Ventura and
ten incorporated Cities to implement requirements of the
Ventura 2010 Municipal Separate Storm Sewer System
(MS4) Stormwater Permit No. CAS004002 since 1992, when
Ventura County Board of Supervisors adopted a benefit
assessment levy for stormwater and flood management in
Ventura County. Since passage of Proposition 218 in 1996,
the assessment rates have not changed, because voter
approval is required. Consequently, annual revenue of
approximately $40,499,155 has not changed, while the
recent annual budget for MS4 Permit/TMDLs compliance
and VC WPD's flood control was over $74 Million* (this
amount does not include Cities' flood control budgets). The
funding gap is supported by the County and Municipal
General Funds, Grant funding, and fund balance, which are
highly variable sources due to competing needs for General
Fund funding, competitive nature of grant programs, and
short-term availability of fund balance. In addition, fees for
municipal services, e.g., inspections of businesses, industrial
facilities, and construction sites, help fund MS4 compliance
activities.
County or Municipality
County of Ventura, Ventura County
Watershed Protection District, and ten
incorporated Cities of Camarillo,
Fillmore, Moorpark, Ojai, Oxnard, Port
Hueneme, Ventura, Santa Paula, Simi
Valley and Thousand Oaks, California
Population
850,967
Annual Rainfall
18 inches
Land Area
2,208 square miles
Poverty Level
9.5% (persons in poverty)
MIHI $81,972
Annual Revenue
$40,499,115
Annual Budget*
$74,129,564
Total Identified Need
$2,305,178,303 (2021-2050 CIP)
$87,530,290/year (O&M after 2050)
Flood protection needs in the County are driven by aging
infrastructure and flood risk reduction. It is estimated that
over 50% of facilities will need to be replaced or rehabilitated within the next 30 years at a significant
cost not supported by current revenues.
The Ventura MS4 Permittees are subject to 16 Total Maximum Daily Loads (TMDLs), of which 13 TMDLs
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approved by the chartered EFAB, and does not represent EPA policy.
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are enforceable after incorporation into the MS4 Permit in 2010. Compliance with the upcoming new
Permit and approaching TMDL deadlines will require for planning and implementation of costly
stormwater treatment structural best management practices (BMPs).
The roughly estimated structural BMP implementation cost for Ventura MS4s are driven by the three
effective and assumed two future watershed-wide Bacteria TMDLs. In particular, the wet weather
compliance is very expensive undertaking for each watershed in Ventura County. Significant new CIP
funding is already needed to meet upcoming 2023, 2026, and 2029 deadlines for existing Bacteria
TMDLs. Past the year of 2050, anticipated as final compliance deadline for future TMDLs and completion
of flood control improvements, the annual operation and maintenance (O&M) cost was estimated at
approximately 3% of the total estimated CIP costs. As discussed with regulatory agencies, the current
and future funding gap continues to be a significant challenge for Ventura MS4s.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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Stormwater Utility,
Lawrence, KS
Flood Risk Reduction, Erosion Control,
Water Quality Protection, and Drainage
Infrastructure Management
Overview
The City of Lawrence, KS, is located 35 miles northwest
of Kansas City. In 1996, the City adopted a Stormwater
Management Master Plan that analyzed the performance
capability of the existing drainage system, recommended
improvements to the facilities, and recommended the
creation of the Stormwater Utility and corresponding
stormwater fee.
History
The 1996 master plan provided a framework for the City to
create and operate a Stormwater Utility. The utility is
responsible for all activities related to the operation of the
stormwater system, including planning, capital facility
construction, street sweeping, and educational programs.
The plan also recommended the implementation of a
stormwater fee to provide a dedicated source of revenue.
The impervious area fee is an equitable means of collecting
revenue from users in proportion to their demands on the
system. In 1996, the fee was set at $2.00 per equivalent
residential unit; this fee was increased to $4.00 by 2003 and
was not adjusted again until 2016. Currently the fee is $4.37.
The City has recently begun a comprehensive stormwater
rate study and financial plan in anticipation of increasing the
size of the utility's capital program and completing the
capital projects identified in 1996.
County or Municipality
City of Lawrence, KS
Population
97,286
Annual Rainfall
39.92"
Land Area
26.3 square miles
17 main watersheds
Poverty Level
21.8%
Total Identified Need
$62 million
Annual Capital Budget
$1.3M
Annual O&M Budget
$1.9 M
Annual Stormwater Revenue
$3,233,000
Capital Needs
The initial master plan identified 41 individual projects at a total cost of approximately $62 million (2019
dollars), while implementing a stormwater fee that would generate approximately $1.2 million per year.
Average revenue has been $2.9 million since 2003, which has been sufficient for annual operating costs
and debt service but left little for new capital facilities. The current five-year capital improvements plan
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approved by the chartered EFAB, and does not represent EPA policy.
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identifies projects totaling $26 million, which the utility plans to meet after paying off its outstanding
debt in 2018 and establishing a program of regular rate increases.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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Metropolitan Water
Reclamation District of
Greater Chicago
Working hard to manage stormwater,
clean wastewater and recover
valuable resources.
Overview
History
Annual Capital Budget
For years, stormwater management in Cook County had been a (fY19 Budget)
patchwork of efforts by local, regional, state and federal
agencies. In 2004, the Illinois General Assembly enacted Public
Act 93-1049 allowing for the creation of a comprehensive
stormwater management program in Cook County under the
supervision of the Metropolitan Water Reclamation District of Greater Chicago (MWRD).
The Metropolitan Water Reclamation District of
Greater Chicago (MWRD) serves approximately 10.35 million
people each day, residents of Chicago and 128 suburban
communities.
Through a variety of engineered solutions, both green and gray,
and flood-prone property acquisitions, MWRD's Stormwater
Management Program addresses both regional and local flooding
problems throughout Cook County.
In 2015, the MWRD adopted a Green Infrastructure Plan to
increase the acceptance and investment of Gl throughout Cook
County. Since that time, the MWRD has partnered with dozens of
agencies to fund Gl projects such as rain gardens,
bioswales/bioretention areas, permeable pavement systems, and
rain water harvesting systems. These projects will provide up to 5
million gallons of stormwater runoff storage to over 1,400
benefiting structures.
County or Municipality
Metropolitan Water Reclamation
District of Greater Chicago, Cook
County
Population
10.35 Million Service Area
Annual Rainfall
38" (Illinois)
Land Area
822.1 sq. mi.
Poverty Level
15.9% (Cook County)
Total Identified Need
The Act required MWRD to develop the Cook County Stormwater Management Plan. The Cook County
Stormwater Management Plan provides the framework for the stormwater management program,
including its mission, goals, and program elements.
The MWRD's countywide Stormwater Management Program's mission is to provide Cook County with
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
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approved by the chartered EFAB, and does not represent EPA policy.
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effective rules, regulations and capital improvement projects that will reduce the potential for
stormwater damage to life, public health, safety, property and the environment.
Under the plan, the MWRD established Watershed Planning Councils and completed Detailed
Watershed Plans for all six major watersheds in Cook County.
MWRD has made significant investments in developing over 140 capital stormwater projects since it
assumed the authority for stormwater management in 2004. These projects, which range in both size
and scope, provide flood protection for thousands of homes, businesses, and critical infrastructure.
Capital Needs & Funding Sources
Public Act 93-1049 gives MWRD the authority to levy a tax and to issue bonds for the development and
administration of countywide stormwater management. Although the District's authority for the
program applies to all of Cook County, the tax levy is only applicable to commercial and private property
located within the District's corporate limits. The District's stormwater management program is
currently funded by the stormwater tax levy.
The District utilizes the stormwater tax levy and additional funding mechanisms to finance the
countywide program.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
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Stormwater Environmental
Utility, Sarasota, FL
Control water quantity, enhance water
quality, effectively manage stormwater
Overview
The County of Sarasota, FL, is located in the coastal plain of
southwest Florida. In 1987, the County completed a
Stormwater Management Master Plan that identified the county's
drainage basins and recommended the enactment of a stormwater
utility fee as a dedicated funding source.
History
The Stormwater Environmental Utility (SEU) was established in
1989 and is organized into four main sections: Master planning,
Capital improvements, Maintenance, and Development review. The
utility is responsible for all activities related to the operation of the
stormwater system, including master planning, the capital
improvement program, inspection and maintenance of the
stormwater management system, and the proper use, storage,
disposal of sediments, herbicides and other materials.
County or Municipality
Sarasota County, FL
Population
419,689
Annual Rainfall
52.99"
Land Area
725 square miles
6 main watersheds
Poverty Level
18.6%
Total Identified Need
$400 million
Annual Capital Budget
Varies
Annual Stormwater Revenue
$21,000,000
The assessment methodology has gone through several legal
challenges and changes since its inception in 1989. As one of the
first stormwater utilities created in Florida, Sarasota County has
been a leader among local governments in developing such a
program. In contrast to the engineering practice of impervious and
flow rate calculations, the rate structure was changed in 1994 to a
system that considers the pervious and impervious areas of each
parcel as the method of assessment (all lands act like impervious
surfaces during 5-yr, 25-hr rain events). The Sarasota County SEU
assesses its customers based on Equivalent Stormwater Units (ESU's) that are based on the effective
impervious area of the average single-family parcel.
Flooding level of Service (LOS) is intended to protect habitable structures up to the 100-yr, 24-hr rain
event. Water quality expectations from regulatory pressures are significant and reach beyond the
Stormwater Environmental Utility to include wastewater treatment and reuse water for irrigation.
Capital Needs
To-date, the SEU has spent about $600,000,000 in stormwater LOS flood improvements, operations and
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
• • •
no
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maintenance. Water quality expenditures for the SEU have been approximately $20,000,000. Current
Total Maximum Daily Load (TMDL) requirements are forecast to have an unmet need of $400,000,000
that will be distributed to various sources of nutrient loading in the County over the next 20 years.
Various sources of local funding are being exercised in public dialog. All typical sources are under
consideration to include sales tax, ad-valorum and special assessments.
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
Ill
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Appendix III: Stormwater Funding Database
As part of its charge, the Task Force lead the development of a database of funding and financing
sources commonly used by communities and municipalities to fund their stormwater infrastructure. The
database is not a comprehensive list of all sources; rather, it is the most commonly used sources at the
federal and state level. Local funding sources, which are often used by municipalities and communities
were not captured in this effort. It was decided by the Task Force that local source vary year to year, and
from community to community so greatly that they would not be able to accurately capture local
options. The complete database can be found on the EPA's Water Finance Infrastructure and Resiliency
Finance Center webpage ( https://www.epa.gov/waterfinancecenter) and has been uploaded to the
Water Finance Clearinghouse.
Data Sources
This section summarizes the variety of sources used to populate the Stormwater Funding Database.
Water Finance Clearinghouse
The Water Finance Clearinghouse, which is a web-based portal that contains information and resources
on drinking water, wastewater, stormwater infrastructure, and other areas within the water sector, was
developed by EPA's Water Infrastructure and Resiliency Finance Center. Within the Water Finance
Clearinghouse, funding sources were pulled by applying a "stormwater" filter to narrow the results to
377 sources, which were then uploaded to Microsoft Access. The data was reviewed for duplicates and
all national federal programs were limited to one entry, since some federal grants were listed several
times but in relation to only one state. The State Revolving Fund (SRF) grants, however, were broken
down into several entries, one for each state/territory.
Federal Funding Programs - Stormwater and Green Infrastructure Projects
The EPA had previously developed this table containing all known federal funding programs that involve
stormwater and/or green infrastructure project components. The sources pulled from the Water
Finance Clearinghouse were cross referenced to this table and any missing data was added.
Stormwater Infrastructure Funding Task Force
The Task Force provided recommendations and documentation of potential sources to include in the
database.
Technical Approach
This section summarizes the different variables, or fields, that were used in the database as well as the
procedure for entering and quantifying the data.
The Water Finance Clearinghouse provided many fields of data that were narrowed down to what was
relevant to the charge, as seen in the table below. A few fields were also added to directly provide
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
• • •
112
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information to help answer some of the charges. A few of the fields were limited to the options
provided in bullets below to simplify filtering the data by source type, agency, funding use, etc. For the
funding amounts, if the source does not have a range and only has a fixed amount allocated each year,
the amount was placed in the max field and the min field was left blank.
Program Name
Name or brief description of source
Source
Who is providing the funds?
Source Type
4
¦I
Taxes/general funds
Fees
II
Stormwater utility
fl!
Grants
4
*
Bonds
Loans
Public-private partnerships
Agency
, ¦" .¦.
Federal
State
Local
4
Private (including non-profit)
Website
URL
State
State or National
How Funds are Issued
4
Application process
4
Fund allocation to states and localities
4
Competitive vs. non-competitive process
4
Long-term programs vs. one-time allocation
Grant vs. loan programs
How Funds are Used
4
Capital
It
O&M
¦1
Compliance
How Funds are Utilized
How are funds coordinated with other sources of
funding?
Funding Amount Min
What is the typical annual minimum amount of
funding amount for this program?
Funding Amount Max
What is the typical annual maximum amount of
funding amount for this program?
Funding Requirements
What are the requirements for receiving these
funds?
Environmental Financial Advisory Board (EFAB) Draft Working Paper—Do Not Cite or Quote
This draft is a work in progress; it does not reflect consensus advice or recommendations, has not been reviewed or
approved by the chartered EFAB, and does not represent EPA policy.
113
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Environmental Financial Advisory Board (EFAB) Draft Letter (1/28/2020) - Do Not Cite or Quote—
This draft has not been reviewed or approved by the chartered EFAB and does not represent EPA policy.
ENVIRONMENTAL FINANCIAL ADVISORY BOARD
Members
Joanne Throw®, Chair
Brent Anderson
Lori Beary
Janice Beecher
Theodore Chapman
Rudolph Chow
Edwin Crooks
Lisa Daniel
Marie Roberts De La Parra
Yvette Downs
Ted Henifin
Craig Holland
Daniel Kaplan
Suzanne Kim
Pamela Lemoine
James McGoff
Chris Meister
James "Tony" Parrott
Eric Rothstein
Angie Sanchez
William Stannard
Carl Thompson
Richard Weiss
David Zimmer
Designated Federal
Officer
Edward H. Chu
Date
The Honorable Andrew R. Wheeler
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460
Dear Administrator Wheeler:
The Environmental Financial Advisory Board (EFAB) is pleased to submit our report, Evaluating
Stormwater Infrastructure Funding and Financing Task Force. This report was developed in
response to Section 4101 of the 2018 America's Water Infrastructure Act (AWIA), which
directed the EPA to establish a Stormwater Infrastructure Funding Task Force. Congress
directed the Task Force "to conduct a study on, and develop recommendations to improve,
the availability of public and private sources of funding forthe construction, rehabilitation, and
operation and maintenance of stormwater infrastructure" to meet the requirements of the
Clean Water Act. This Task Force was convened under the EFAB as a workgroup and the EFAB
approved this report and accompanying recommendations at our public meeting on .
We believe that effective stormwater management is integral to American quality of life. The
construction, rehabilitation, and operation and maintenance of stormwater infrastructure is
widely viewed as a solution to improving water quality in our nation's waterways, reducing
local flooding problems, and enhancing community resiliency. More than 80 percent of the
U.S. population lives in a community that has a stormwater permit and that number continues
to grow.
Stormwater management costs have been steadily increasing at the local level and many
communities do not have a sustainable source of funding for their stormwater programs. The
limited availability of low-cost funding through debt financing, grants, and user fees
exacerbates the growing affordability challenges that many communities face in paying for
their stormwater infrastructure and programs. Stormwater funding is a national problem that
requires action.
The Task Force was charged with the following questions to explore and develop potential
solutions in improving the availability of stormwater funding:
• Identify existing federal, state, and local public and private sources of funding for
stormwater infrastructure.
• Assess how the source of funding affects affordability, including costs associated with
infrastructure finance.
• Assess whether these sources of funding are sufficient to support the capital
expenditures and long-term operations and maintenance costs required to meet
municipalities' stormwater infrastructure needs.
Creative Approaches to Funding Environmental Programs, Projects, and Activities
-------
Environmental Financial Advisory Board (EFAB) Draft Letter (1/28/2020) - Do Not Cite or Quote—
This draft has not been reviewed or approved by the chartered EFAB and does not represent EPA policy.
The Task Force analyzed the funding needs of communities across the country and the funding sources that can be
used to meet these needs. From this information, the EFAB has six recommendations that are organized underthree
categories: (1) Stormwater funding education and technical assistance, (2) Simplification of existing federal grant
and loan programs and affordability support, and (3) Dedicated federal stormwater funding assistance.
These recommendations are presented as actionable ways to use existing funding, increase accessibility to those
funds, and identify additional funding opportunities. Several of the recommendations include direct engagement by
the EPA with state and local agencies. This two-way exchange will help bridge the gap between the source of clean
water regulations (federal) and the most important source of funding (primarily local). This, in turn, will also greatly
benefit the overall goals of the Clean Water Act, the involved agencies, and the public at large.
EPA is required to submit a report to Congress no later than 18 months after enactment of the 2018 AWIA (by April
2020) describing the results of the Task Force's study and resulting recommendations. We hope this report is helpful
to the EPA and we look forward to your report to Congress on this important matter.
cc: Edward H. Chu, Designated Federal Officer, Environmental Financial Advisory Board
David P. Ross, Assistant Administrator, Office of Water
Benita Best-Wong, Principal Deputy Assistant Administrator, Office of Water
Dr. Andrew Sawyers, Director, Office of Wastewater Management
Raffael Stein, Director, Water Infrastructure Division
Sonia Brubaker, Director, Water Infrastructure and Resiliency Finance Center
Sincerely,
Joanne M. Throwe, Chair
Environmental Financial Advisory Board
Rudolph Chow, Co-Chair
EFAB Stormwater Infrastructure
Finance Taskforce
Enclosure
-------
U.S. Environmental Protection Agency
Environmental Financial Advisory Board
Consideration of the Stormwater Infrastructure Funding Task Force Report
Pre-Meeting Comments from EFAB Members
Developed in preparation for the February 11-13, 2020 meeting of the EFAB.
Table of Contents (as of 2/6/2020)
Comments from Brent Anderson: 2
Comments from Janice Beecher: 3
Comments from Edwin Crooks: 5
Comments from Dan Kaplan: 7
Comments from Suzanne Kim: 8
Comments from Richard Weiss: 14
Comments from David Zimmer: 16
-------
Comments from Brent Anderson:
Executive Summary: I would add a brief paragraph describing what stormwater is. It will frame
the rest of the Executive Summary, and for those that never read beyond the Executive
Summary, context for the problem and recommendation
Page 10: Key Terms. I would clearly state that the issue is one of water quality, not to be
confused with water quantity.
Page 14, Section 3.1.1: The word "utilities" is used throughout the document. This approach
works in metropolitan areas, but much less so in unincorporated areas.
Regarding the Recommendation on technical assistance: I think the technical assistance should
also include cooperative basin wide projects. The focus on federal and municipal funds likely
results in a more ad hoc solution because projects have to follow the funding. Technical
assistance that addresses problem in a coordinated basin context would likely reduce costs. It
could result in additional (though more complex) funding opportunities.
Page 15, Section 3.1.2: This is a great recommendation, and to the extent we address Federal or
any other state funding, we should always make it.
Page 16, regarding SRF as an integral tool: Conditioning access to SRF support on intra-basin
solutions could be used to get different participants to work toward an economical common
solution.
2
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Comments from Janice Beecher:
• The report is ambitious, well-organized, and dense with information; case studies
add value (although I did not review them carefully).
• It would benefit greatly from close editing by people with technical expertise in
specific areas; for example, I took a swing at a paragraph on "private investment"
(see below)
• The evaluation criteria (Sec. 6.2.2.1, page 67) were not entirely clear to me in
terms of interpretation, and in some instances, I disagree with the "score."
• It is very important to avoid conjecture and assertions that may not be evidence-
based; add a citation, a caveat, or delete.
• Be careful not to conflate sources of funding, means of financing, and
organizational entity (government, utility).
Page 48: the private sector does not provide "financial assistance." Neither do finance
companies. You do not "apply for private investment". Regarding the statement on private
sources of capital being more expensive but more accessible than public sources: is this evidence
based?
i Private Investments: Private investment can take the form of loans and/or other financial
assisiaf>€e-«figmatmg4fefB-courcec other than commefeia-S-baffe and/or finance compamesr
debt or equity instruments. Sources of private capital investment can include_o, but arc not
limited to, insurance companies, pension funds, venture-€apfta44m^S7-m^¥fdwa4-venture
¦ea-pttatisfeor private equity (fund or individuals), corporation partnefs-a-Rct-gefteral capital
wwestefSrand publicly traded companies. Investor-owned utilities utilize both the private
equity and shareholder models. Private investorsmont ftm4s-finance billions of dollars' worth
of_ now business start-ups in the United States each year. The potential uses of private
investment for supporting environmentally related businesses and/or activities arc only
timtte4is based on perceptions of by the-4eefee-ef-Bfeft-asse€late4-wfth-#>emprofitabilitv.
which for investor-owned utilities is usually subject to state economic regulation due to their
monopoly status. In fact, the creation of a privately owned utility may trigger state
jurisdiction. The cost of public or private capital is based on anticipated returns relative to
risk. : if it can bo shown that an idea or activity will make money, then private investment can
be found to support it. Applying for private investment is typically much faster than for
gevemmef>$4eaR-efegfamsrPrivate sources of capital are more expensive but, in some cases,
may be less limited and more accessible than public sources. -Pf+vate4ftvestors usually have
f>e-set-etigtbttity-€frtefia-af>4-may have-fte-pfedetefmmed-Umte on the total amount of loan
ea-pttal-availa-bleT-Private investment generally demands efs4end to demaftd-a-significantly
higher rates of return than public sources eenfeeif-mwev. though, than otheF-sources- of
capital. Private investment can also be part of a public-private partnership or hybrid model.
Note that a private-mvestment can develop into a public-^wvate-paftftefship of an
operational componefrt4s-ad^e44e-#te-mkT
Page 50: add citation
3
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5.2.3.I Public-Private Partnerships
Public-private partnerships (P3s) are receiving incroasinggaining attention in the United States
and internationally as an innovative way of financing a wide range of different environmental
protection initiatives. PThc point of P3g is that partnering with private enterprise can expand
access to resources and capital and offer better potential economies of scale. There are many
types of P3s: design^build, design^/build^operate^/maintain, pay-for-performance
(interchangeable with pav-for-success) contracting, community-based P3s, etc. They may include
private financing or a combination of public and private financing. According to [cite],
c€ommunity-based P3s have a
Page 69: Table 2
Table 1. Financial Capacity Impact of Recurring/Intermittent Funding Sources—O&M Operations.
Do these eval criteria really track here? low, hi, volatile?
Household
Affordability
Impact
HigbModerate:
property taxes
aro generally
doomod as
rogroG
ModerateH4gk:
property taxoG aro
gonorally doomod
ao rogroooivo
Moderateiow: User
fees are s&U
Gomowhat
regressive but may
beuGually much
smaller in actual
dollars compared to
water and sewer
charges
Moderatetow: if tied
to a "user pay" levy,
would mostly likely be
borne by those
directly benefitting
from the
infrastructure
Moderate: not as
regressive as a pure
tax but still
correlated to
property valuation
without explicit
income recognition
Household Affordability Impact: oversimplification - property taxes are not necessarily
considered regressive, and are certainly less regressive than user fees.
4
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Comments from Edwin Crooks:
In general, I think this is an excellent document - thorough, thoughtful and well-written. A couple
points we might want to address include:
Section 3.1.3: I'm struggling a little with the first recommendation about building a national
database. No doubt it would be good to have the info available, but it sounds like a very heavy lift
and I question whether it would be very impactful to addressing the core challenges of
stormwater financing. If the EFAB wants to keep this recommendation I think we need to beef up
the argument for how it would make things better and give a good rationale for EPA to invest
time and money in doing it.
Section 5.2: This section title should be changed to "Stormwater Funding and Financing". It might
seem like semantics, but there is a big difference between funding and financing and we blur the
lines here. The core problem of this entire charge is summarized in the first sentence of the
"Revenue" discussion - the need for ongoing stable and meaningful funds. To the extent that
funding flows can be increased and made more predictable, financing becomes cheaper and
more readily available and lots of problems can be solved. But I think we need to highlight the
differences in funding and financing in this section and discuss the linkage between the two.
Section 5.2.1.1.2: The subject of tax increment financing is mentioned later in section 5.2.3.5 but
I think we ought to tee it up here as a subset of the universe of special taxing districts. This can be
an important tool and I feel it is somewhat buried in its current location.
Section 5.2.2.1.1: The call out box about green bonds caught my eye for two reasons. First, it says
these are tax exempt instruments. While they usually are tax exempt, there is no reason that a
taxable bond couldn't be green as well. Then further down it says that these bonds are of interest
to "younger investors", which I would dispute. Also, this appears to be a quote but there is no
attribution to a source.
Section 5.2.3.1: In the first sentence we talk about P3 only as a financing mechanism, but we
should describe it as a holistic approach to project delivery, including financing. In the second
sentence we should add some mention of the potential for P3's to deliver more creative and
efficient technical solutions to stormwater projects.
Also in this section there is no mention of another financing source used in P3 deals, which is
private investor equity. I suggest we add a blurb somewhere here that says something like
"Financing for P3s also typically includes private investor equity as another source of capital.
Investor equity is very flexible, typically patient capital that instills a level of rigor in the private
operator's management of the stormwater asset. This is relatively expensive financing, however,
and typically requires that the public project sponsor cede some level of control to private
investors."
Section 5.2.3.5: The second bullet on tax increment financing needs to be corrected to say:
"...increase surrounding property values and the incremental tax on the increased property value
is dedicated to funding the new infrastructure. In addition, owners of those properties may also
agree to a new tax levy..."
5
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Section 6.0: It seems to me that this section is missing one very important observation about how
the funding sources affect affordability. When municipalities are faced with insufficient funding
they will often default to a "pay as you go" approach, meaning they will only build the
improvements they can afford at that time. This means that larger projects have to be split up
into multiple pieces that are procured and constructed separately over many years. This is
inherently more expensive than building larger projects because it requires the municipality to
conduct multiple procurements, each with its own transaction costs, oversight requirements, etc.
Meanwhile the municipality is left with the added risk of coordinating and integrating what may
become a patchwork quilt of improvement projects. In addition, the community and
environmental benefits of completing the entire project are delayed.
If the municipality's funding sources were more robust and predictable, bond financing could
become an option that would enable larger, more impactful projects to move forward. These
projects and their benefits could be completed earlier and with less transaction cost and residual
risk for the owner. And as funding sources become more and more robust and more
creditworthy, the cost of borrowing should decline.
These points are applicable to several subsections of chapter 6.0 but should probably be
addressed more explicitly somewhere in the chapter.
6
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Comments from Dan Kaplan:
The second paragraph in 1.2 of the Executive Summary gives disproportionate emphasis on
innovative funding strategies relative to what is presented in the report. The body of the report
is clear that the preponderance of new funding sources will be local. This Executive Summary
section should discuss how local communities need technical support for the creation of
stormwater utilities and revenue systems, including assistance in accessing innovative
approaches. This would provide a better tie-in to the first recommendation.
The draft report is inconsistent on the role of other federal funding programs. Section 2.4
delineates funding needs not included in the report, including agricultural pollution, but the final
recommendations calls for a set aside for federal farm subsidies. I agree with this
recommendation, but it should be supported within the report with a section on pollution caused
by agricultural runoff.
The recommendation and supporting narrative (page 18) on the national data base to enumerate
state barriers for the creation of stormwater utilities and fees should be moved to the education
and technical assistance section and out of funding assistance. And can it be stronger? "States
are encouraged to eliminate barriers to the creation of stormwater utilities and user fees to
support them." And for funding assistance, "Federal assistance programs should prioritize
funding to those communities with dedicated stormwater utilities."
Section 5.0, page 29 includes green infrastructure as a factor that has increased the average cost
of stormwater programs. This bullet should be deleted, as green infrastructure is a response to
challenges enumerated below that bullet and not a cause per se. I would include an additional
bullet: "New investments for complying with CSO consent decrees and MS4 permits."
Lost in the discussion and tables on funding sources is any mention of wastewater fees, which are
used by many utilities to support stormwater operations. Rather than clutter the table, a
paragraph on cross-subsidization and equity could address this.
Page references for the case studies on page 80 would be helpful.
7
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Comments from Suzanne Kim:
There is a tremendous and laudatory amount of work accomplished in a very short period of
time. My comments are focused on the Executive Summary as this will be the primary vehicle to
communicate the contents of the report.
1) The Executive Summary needs to be absolutely tight. I have attached my suggested edits
to the Executive Summary (I didn't include comments #4 & #5).
2) Funding = free money, like grants. Financing is money you have to pay back...like loans
and equity capital. You need to distinguish between the two. Funding DOES NOT =
Financing. This section must distinguish between the two and communicate this
distinction.
3) Also Funding/Financing is different from Revenue... Revenue is what utilities need to
access debt capital. Revenue is leveraged to access financing. IT IS NOT
FINANCING. There is confusion throughout the executive summary conflating the two
concepts. Revenue is not funding nor financing
4) At the last EFAB meeting, there was considerable discussion on whether there is enough
capital out there in the current programs to support the capital needs and or whether
the problem is accessibility (how it is marketed and who can access it). In the Executive
Summary, we need to establish whether we want to push for additional capital, better
access, or both? Let's be clear.
5) In the executive summary the author asserted that there has been no comprehensive
national survey done to determine the magnitude of the funding and financing shortfall—
-if so, that survey/analysis/study absolutely needs to be in the recommendations. How
can one justify that the federal government appropriate additional $s ("billions" is
vague—is it tens of billions? Hundreds of billions?) if it the quantity is unknown? If there
truly has been no study, someone has to do one. Therefore, it should be in the
recommendations.
8
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1.0 Executive Summary: Stormwater Funding: A National Problem That
Requires Action
tormwater management is
as wastewater management and safe drinking water
stormwater management
rinking water and wastewater management services
through the utility have matured
reliable services
sources of
funding . , Clean Water
State Revolving Fund programs have provided $133 billion in assistance, mainly in the
form of low-cost financing, to a wide range of eligible borrowers. The utility
effective and
, has worked well the drinking
water and wastewater sectors should be stormwater ,
the next
water quality
^Unfortunately,
1,600 of the 7,550 permitted stormwater entities in the United States have
dedicated revenue sources stormwater
user fees (also known as stormwater utilities where fees are based, for example, largely on
impervious area), taxes, established drainage districts that collect dedicated funding for
stormwater
D i 14- rrwtrw
"j-j" %. UTvi i %Ji C« Cm > I V i£e v» i i; ij.'w PrvM'i'vtuiO'iw UT'm ^ i.w" irv.''v'wi~
If 4-U 4'hia ry t ry ry 4" «¦» <-%frry ir\ /-\ffsry ry &-%. ry r .i bwu>w ^ tinJ^TCi'"i"i Cfrtij K*rc*',CNj » w i b"'v* jM'w i tJi C« <->» gsJig
tormwater jurisdictional boundaries and
state, ¦
biwctef&atjd federal entities. Therefore, meaningful cross jurisdictional partnerships underlie
here no comprehensive
9
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assessments conducted at the national level to determine the magnitude of the funding and
financing capital needed to construct, operate, and . and adoquatolv maintain and oporato
stormwater infrastructure across the country nationally. Recently, there have been some Recent
regional . limited surveys that have attempted to estimate the funding and financing shortfall in
the stormwater services sector. These limited studies concluded that the annual shortfall is
somewhere in the neighborhood of billions. [Kim: "billions" is not adequate—please cite
something]
challenge, local funding efforts arc not enough. Because of the cross jurisdictional nature of
stormwater management and because the amount of and access to capital via current funding
and financing programs are inadequate to construct, operate, and maintain effective stormwater
management across the country, the Task Force recommends that the federal government
invests in stormwater infrastructure, similar to how the federal government established There
is a nood for fodoral invostmont in stormwator infrastructure, similar to tho lovol of invostmont
that-federal funding and financing programs have-providod in the past to begin buildingthat
have built our interstate highway system, upgrade our wastewater infrastructure, w-and
deliver d safe drinking water to our homes. Tho fodoral financing and funding framework that
has worked so woll to support tho drinking water and wastewater sectors should bo adapted to
fund solutions to the stormwater challenge. _This type of federal financing and funding will
support communities with stormwater permits that serve more than 80 percent of the U.S.
population. Therefore, stormwater funding is a national problem that requires action.
1.1 Stormwater Infrastructure Funding & Financing Task Force Report and
&_Charge
This report was developed n response to Section 4101 of the 2018 America's Water
Infrastructure Act (AWIA), which diroctoc the Environmental Protection Agency (EPA) te
establish d a Stormwater Infrastructure Funding & Financin Task Force "Task Force") "to
conduct a study on, and develop recommendations to improve the availability of public and
private sources of funding for the construction, rehabilitation, and operation and maintenance of
stormwater infrastructure" to meet the requirements of the Clean Water Act.
Specifically, the iPA charged the Task Force with the following tasks:
4 Identify existing federal, state and local public and private sources of funding and financing
for stormwater infrastructure (addressed in Section 5.0)
4 Assess how the source of funding and financing, including the costs associated with
infrastructure finance affects affordability including costs associated with infrastructure
4 Assess whether these sources of funding and financing are sufficient to support capital
expenditures and long-term operational and maintenance costs required to meet the
stormwater infrastructure needs of municipalities (addressed in Section 4.0).
The charge has culminated in the attached report.
gomont and infrastructure fundi
nding lovols. Without question, 1
thoro is a pressing nood to contir
41y
3r funding sources that do oxist aro typically insufficient for currently
s. Givon tho magnitude and cross jurisdictional nature of tho stormwator
in Section 6.0) andr
10
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1.2 Local Stormwater Funding
Efforts
onversations
have shifted from "how to develop
stormwater utilities" to innovative funding
strategies^
public-private partnerships, incentives for private property owners to
implement stormwater controls, green bonds, and trading schemes. Innovative funding
,coupledwith traditional mechanisms (e.g., stormwater
utilities, fees-in-lieu-of, drainage/taxing districts) provide local programs with
alternatives to their stormwater needs.
1.3 Federal Stormwater Funding Support
federal investment in stormwater infrastructure, similar
to the level of investment that federal funding programs have provided in the past to, among
other , our interstate highway system, upgrade our wastewater
infrastructure, and deliver safe drinking water to our homes.
The federal government can allocat funding for
stormwater programs from existing related programs to ensure that infrastructure is properly
maintained and that future infrastructure planning, designtand capital expenditures are
conducted using industry best practices.
Municipalities and local utilities need federal and state help in long-term
reliable funding sources. Funding must be available in all states and be sufficient to support both
capital expenditures and long-term operation and maintenance costs.
1.4 Recommendations
Task Force recommendations are practical to implement, actionable
at the federal levelt and understandable to the public. uggestions
increasing accessibility to and education of existing funding and financing programs,ta tiss
existing funding ,
11
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additional funding
Task Force's recommendations
are :
§ Stormwater funding education and technical assistance. Educating the public and elected
officials on the need for stormwater is critical to the successful
implementation of and community support for funding solutions. In addition,
many communities need technical assistance to evaluat and secur funding
and financing
Recommendation: Educate elected representatives, professional administrative leaders
and the general public on the need for sustainable local stormwater funding and
organizational capacity through, for example, the creation of stormwater utilities or the
expansion of existing utilities into the stormwater sector.
I Recommendation: Provide technical assistance and funding to help communities create
sustainable funding sources. This could include assistance with funding need assessments,
organization analysis, grant applications, and/or establishing a stormwater utility fee.
ft Simplification and/or modification of existing federal grant and loan programs and
affordability support. Federal grants, loans (e.g., from State Revolving Funds) and support to
enhance affordability are needed to maintain sustainable local funding sources.
I Recommendation: Provide for a common application for differ en t federal grants across
all federal agencies.
Recommendation: The State Revolving Fund (SRF) is an integral tool among the many
infrastructure financing options available to communities. Whether stormwater receives
consideration of its own through a new SRF program, or receives less restrictive eligibility
considerations and larger appropriations within the existing Clean Water SRFs (CWSRF) or
eligible Drinking Water SRF (DWSRF) projects, it is the view of the Task Force that
stormwater would benefit from an additive - not zero-sum - recurring financial
commitment from EPA. This could be achieved by the implementation of one or more of
the following, each of which is outlined below:
o Create a new SRF program exclusive to stormwater programs and projects.
o Expand the existing Water Infrastructure Finance and Innovation Act (WIFIA)
program or fund the Army Corps of Engineers' Water Infrastructure Program also
established in 2014.
o Create a specific stormwater set-aside in the existing CWSRF framework and increase
awareness/ guidance on the CWSRF for stormwater projects, including the Green
Project Reserve program.
I Recommendation: Use federal funding or technical assistance to help utility customers
who are financially struggling to pay their water, sewer, and stormwater utility bills
(similar to Low Income Home Energy Assistance Program (LIHEAP)).
§ Dedicated federal stormwater funding assistance. Given the magnitude of the stormwater
12
-------
needs described in this report, there is a need for federal investment similar to the
investments in the National Interstate Highway system and historical wastewater treatment
plant upgrades.
Recommendation: Build comprehensive national database that enumerates state
barriers to implementation of new dedicated stormwater revenue sources such as user
fees or other revenue sources, and/or any state restrictions on existing fees and charges.
Recommendation: Increase annual funding allocation for and modify the 319(h) grant
program to allow and encourage local capacity building, utility fee study and
implementation, asset management, and remove restrictions on use of grant funds for
MS4 permit compliance.
Recommendation: Develop a new construction grant program specifically for stormwater
projects, similar to the federal Municipal Construction Grants Program that funded the
construction of wastewater treatment plants.
Recommendation: Given the link between agricultural pollution and mandated
stormwater pollutant reduction targets for impaired streams, a Farm Bill Federal subsidy
dedicated to stormwater programs would also be valuable. Require 10 percent of US
federal farm subsidies (all programs) be re-directed toward stormwater/nonpoint impacts
in same watershed where recipient farm is located.
13
-------
Comments from Richard Weiss:
In general, I thought that the report was very thorough and informative. The charge questions to
the workgroup were adequately addressed. It was clear and logical with recommendations
supported by the body of the draft report. Following are some comments on various sections of
the report for the workgroup's consideration.
Page 4 - Section 1.4 recommendation for a new construction grants program for stormwater
projects similar to the federal Municipal Construction Grants Program for wastewater projects
could be viewed as an inefficient way to get funding to communities. However, page 19 mentions
the use of the SRFs as well as other modifications which would make the proposal more efficient
than the original Municipal Construction Grants Program. Suggest modifying the
recommendation to make it clear that this recommendation is not a repeat of the prior program.
The Section 1.4 recommendation to carve out 10% of US federal farm subsidies to be redirected
toward stormwater/non-point impacts in the same watershed was unclear to me. See my
comments on page 20.
Page 5 - First paragraph second line insert "management" after "capital program".
Page 17 - For III, an additional Disadvantage of the specific stormwater set-aside in the existing
CWSRF framework is the potential for reduced funds available for non-stormwater projects if the
CWSRF grant funds are not increased to accommodate this.
For IV, what is meant by "equal weighting"? Funding for the three infrastructure needs may not
be equal. Perhaps revise to say "Create a "One Water" SRF that includes drinking water, clean
water and stormwater."
Page 19 - To the extent that there is a Stormwater Construction Grants Program, it would be
efficient for the federal government to provide capitalization grants to the SRFs. To affordability,
there could be meaningful principal foregiveness on each loan originated by the SRFs (particularly
for disadvantaged communities). This approach would eliminate the need for a local match as
was the case on the wastewater Municipal Construction Grants Program.
Page 20 - For the requirement that 10% of U.S. federal farm subsidies be redirected toward
stormwater/nonpoint impacts in the same watershed - how was this percentage determined?
What would be the impact on farmers of this carve out in various commodities market
environments? How would this impact project development to the extent that farm subsidies
vary from year to year? Who would determine the projects, oversee the expenditure of these
funds, and the completion of these stormwater/non-point projects?
Page 36 - In the chart for the Coordination with other Municipal Departments and State
Agencies, one could also include the concept of merging stormwater functions into an existing
water and/or wastewater utility to get greater coordination as well as operating and capital
spending efficiencies. Stormwater could still be a separate enterprise of the utility. The concept is
addressed later in Section 6.1.2.
14
-------
Page 41 - "WKIT referenced in the second full paragraph. Suggest defining it in the first full
paragraph after "Western Kentucky University". In the second paragraph, there is reference to
$2.2 billion in utility fees with 20% coming from Chattanooga. If these are annual fees, that would
imply $400 million for the City. Text here should be checked.
15
-------
Comments from David Zimmer:
Overall, great paper. I have some minor additions I hope will add value. My general thought is
that the paper might consider shedding a bit more light on the need to educate and help local
officials with quantifying how much effective storm water management policies and their
corresponding projects will save their constituents - in macro-economic terms to offset the rate
costs from the SW utility's projects (e.g. savings from mitigating the occurrence and costs of
flooded basement and car repairs, business interruption costs, commuter down time from
flooded streets or blocked roadways).
If the narrative includes language in dollars and cents - especially if the projects become net
positive for the community, it becomes an easier sell to get behind. I noticed some comments in
this regard, but they seemed to be minor mentions.
Page 3: Recommendations
Should consider including the cost of inaction (i.e. relative cost of choosing to do nothing):
Recommendation: Educate elected representatives, professional administrative leaders
and the general public on the benefits of and need for sustainable local stormwater
funding and organizational capacity through, for example, the creation of stormwater
utilities or the expansion of existing utilities into the stormwater sector.
Regarding the recommendation about a new SRF program ("Create a new SRF program exclusive
to stormwater programs and projects"): I know there were 2 SRFs involved in the writing of this
fine paper. I would take issue with the part of this recommendation for the possibility of a 3rd
separate SRF Program. There is enough infrastructure in the CWSRF to handle this already...
additional segregated funds maybe, but not a new SRF program with its own division w/in EPA.
Page 14, Section 3.1.1 Stormwater funding education and technical assistance
In addition to Water Quality benefit, need to include related concept that SW Mgmt also
promotes economic improvement from the mitigation of the destructive forces of floods,
standing water, etc. Also, nice segue into next parag.
Recommendation: Educate elected officials, professional administrative leaders and the
public on the need for sustainable local stormwater funding and organizational capacity
through, for example, the creation of stormwater utilities or the expansion of existing
utilities into the stormwater sector. Sustainable funding for stormwater infrastructure
builds long-term financial capacity, improves operational performance—and over time
produces results for citizens and residents. For over two hundred years, this has been the
experience with drinking water and wastewater utilities in this country. The educational
goals for these three audiences will demonstrate that stormwater management
investment directly benefits the health, safety and economic opportunity for citizens and
residents through the overall improvement of water quality and resiliency of the
community.
16
-------
Page 16:
I. Create a new SRF program exclusive to stormwater programs and projects.
o Advantages
¦ Replicates programs that have been proven successful for decades.
¦ Would eliminate 'competition' with wastewater projects inherent within
the current CWSRF program.
o Disadvantages
¦ Would require the creation and passage of new enabling legislation to
establish a new SRF program.
¦ Would create a new layer of bureaucracy with cross over and potential
duplicity with the Clean Water SRF Program, both of which are legislated
through the same, CWA.
Page 17:
II. Create a specific stormwater set-aside in the existing CWSRF framework and
increase awareness/ guidance on the CWSRF for stormwater projects, including
the Green Project Reserve program.
o Advantages
¦ Would not require new federal legislation.
¦ Preserves each states' ability to administer the program to maximize
efficiencies and effectiveness specific to each states' needs.
o Disadvantages
¦ Might not improve best management practices or capability of
communities if the set-aside is viewed by them as an implicit high
likelihood/guarantee to get funded.
This statement (under disadvantages) seems to contradict the argument above of the
outstanding need for storm water projects. If the need is great and the funding is available, the
logic would dictate that there will be demand.
Page 22: "Without low-cost concessionary debt, there is no compelling desire for outside, private
capital to invest." What about the developing market for "Impact bonds"?
Page 23: Affordability is, however, an issue for lower-income segments of the population across
the nation, typically the sector in each community most impacted by the lack of proper storm
water management policies:
Page 47:
17
-------
CWSRF: One of the most commonly used loan programs in the wastewater sector is the CWSRF
loan. Under Title VI of the 1987 Clean Water Act, states receive federal monies to capitalize
CWSRF loan programs. Through CWSRF programs, loans are made to communities to provide
low-cost financing for a wide range of different projects to protect water quality. Examples of
activities funded with these loans include nonpoint-source pollution control, watershed
protection and restoration, estuary management, wetlands restoration, brownfields remediation,
and improvements to municipal wastewater treatment infrastructure. Loans are made at low
interest rates (0 percent to market rate) for terms of up to 20 years. In addition, states use
CWSRF money to repurchase debt to get these loans to 30 years. States may set the criteria for
determining which municipalities can access the loans each year. All 50 U.S. states and Puerto
Rico operate CWSRF programs. States have the option to offer a portion of their annual CWSRF
grants as subsidization in the form of principal forgiveness or to buy down the interest rates on
their borrowers' debt. CWSRF grants may also be used to guarantee loans as a way to increase
the leverage and capacity of their lending programs. Combining guarantees and interest
buydowns in a low rate environment, such as exists today, can be a very effective method for
States to offer additional financing to local communities at levels well below market rates. Some
CWSRF and Drinking Water State Revolving Fund (DWSRF) loan programs make short-term loans
for planning, design and initial construction in localities that may later receive long-term CWSRF
and DWSRF loans. In addition, state revolving fund loans may be used to pre-finance other
federal or state drinking water loans or grants
Page 49, Section 5.2.2.1.4
Reference Footnote: https://www.goldmansachs.com/media-relations/press-
releases/current/dc-water-environmental-impact-bond-fact-sheet.pdf for the insert suggested
below:
In addition to more traditional funding sources discussed previously, there are new and evolving
approaches to funding stormwater management that could be leveraged in many cases. These
include public/private partnerships, private site stormwater development, impact bonds such as
the DC Water Environmental Impact Bond and volunteer programs. The ability to utilize such
approaches, and the impact to the stormwater program vary but are important options to
evaluate in developing a comprehensive funding strategy.
Page 76:
For the sentence, "In addition, the use of MHI as an affordability metric has been widely
criticized," I also recommend footnoting a paper by one of the leading voices on the problems
with MHI, Texas A&M Associate Professor, Manny Teodoro: http://mannyteodoro.com/wp-
content/uploads/2017/08/MTeodoro_Affordability-Method-Working-Paper-Aug2017.pdf
18
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Agriculture
Best
Management
Practices
(AgBMP) Loan
Program
Minnesota
Department of
Agriculture
Loan
State
Water quality program that provides low
interest loans to farmers, rural landowners,
and agriculture supply businesses. The
purpose is to encourage agricultural Best
Management Practices that prevent or
reduce runoff from feedlots, farm fields,
septic systems, and other pollution problems
identified by the county in local water plans.
Application steps are found here:
http://www.mda.state.mn. us/grants/loans/a
gbmploan/borrower.aspx
http://www.
mda.state.mn
.us/agbmp
Application
process, Loan
program,
Long-term
program,
Non-
competitive
process
Other
Use local banks as
lenders. Projects are
managed by local soil and
water conservation
districts or county
environmental offices.
None
Average loans between $12,000 to
$115,000 depending on project
type.
Loans for farmers, rural landowners,
and agricultural supply businesses.
Project must address local water
quality priorities. Septic work can be
funded for anyone. Water quality
cooperatives are also eligible.
MN
Alabama Clean
Water State
Revolving Fund
(CWSRF)
Alabama
Department of
Environmental
Management
(ADEM)
Loan
State
Alabama's Clean Water State Revolving Fund
(CWSRF) is designed to be a perpetual
source of low-cost financial assistance for
the construction of public water supply
facilities needed to meet compliance
standards and clean water requirements.
The pre-application form is available online
at
http://www.adem.state.al.us/DeptForms/For
m340.pdf. ADEM will evaluate the pre-
applications according to the integrated
priority system. All projects that score above
the funding line will be invited to submit full
applications. Upon final review and approval,
loans will close typically within six months.
http://www.a
dem.state.al.
us/programs/
water/srfguid
ance.cnt
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan repayments provide
a continuing source of
funds for additional
projects.
$44.8 million
"Projects must strengthen
compliance with Federal and State
Regulations and/or enhance
protection of public health." Projects
must be public water and wastewater
infrastructure improvements and
stormwater/non-point source
projects in the state.
AL
Alabama
Drinking Water
State
Revolving Fund
(DWSRF)
Alabama
Department of
Environmental
Management
(ADEM)
Loan
State
States can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Applicants must submit a preapplication
form to be listed on the Project Priority List
(PPL). The application process proceeds once
on the PPL. Application documents and
guidance are available via ADEM's website.
Application documents available at:
http://adem.alabama.gOv/programs/water/s
rfguidance.cnt.
http://www.a
dem.state.al.
us/programs/
water/srf.cnt
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, best management
practices (BMPs), physical barriers or
security to protect water sources,
local ordinance development, and
more.
AL
Alaska Clean
Water State
Revolving Fund
(CWSRF)
Alaska
Department of
Environmental
Conservation
(ADEC)
Loan
State
The Alaska Clean Water Fund (ACWF) offers
low interest loans to Alaskan municipalities
and other qualified entities for financing
wastewater and water quality related
projects.
Additional information and materials located
at: https://dec.alaska.gov/water/oasys/
https://dec.al
aska.gov/wat
er/technical-
assistance-
and-
financing/stat
e-revolving-
fund/
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan repayment funds
future projects.
None
Eligible entities include
municipalities, and other qualified
entities. Must complete a Fiscal
Sustainability Plan and submit with
application.
AK
Alaska Drinking
Water Fund
(ADWF)
Alaska
Department of
Environmental
Conservation
(ADEC)
Loan
State
States can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents are available at:
https://dec.alaska.gov/water/technical-
assistance-and-financing/state-revolving-
fund/guidance-and-forms.
https://dec.al
aska.gov/wat
er/technical-
assistance-
and-
financing/stat
e-revolving-
fund/
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, best management
practices (BMPs), physical barriers or
security to protect water sources,
local ordinance development, and
more.
AK
1
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Alaska
Municipal
Matching
Grant (AMMG)
Alaska
Department of
Environmental
Conservation
(ADEC)
Grant
State
Provides partial funding and engineering
support for drinking water, wastewater
(sewer), solid waste and non-point source
pollution projects, such as water body
restoration and recovery. These state grants
primarily assist the larger communities and
boroughs in the State.
https://dec.al
aska.gov/wat
er/technical-
assistance-
and-
financing/stat
e-revolving-
fund/grant-
overview/
Application
process,
Grant
program,
Long-term
program
Capital, Other
Grants can serve as a local
match for Alaska Clean
Water Fund (ACWF) and
Alaska Drinking Water
Fund (ADWF) programs.
Grants are primarily awarded to
larger communities and boroughs in
the State. Eligible projects include:
drinking water, wastewater (sewer),
solid waste and non-point source
pollution projects.
AK
Appalachian
Regional
Commission
(ARC) Grants
Appalachian
Regional
Commission
(ARC)
Grant
Federal
The Appalachian Regional Commission (ARC)
awards grants and contracts from funds
appropriated to the Commission annually by
Congress. Program grants are awarded to
state and local agencies and governmental
entities (such as economic development
authorities), local governing boards (such as
county councils), and nonprofit organizations
(such as schools and organizations that build
low-cost housing). ARC provides funds for
basic infrastructure services, including water
and sewer facilities, that enhance economic
development opportunities or address
serious health issues for residential
customers.
Almost all program grants originate at the
state level. Potential applicants should
contact their state ARC program manager
(https://www.arc.gov/about/StateProgramM
anagers.asp) to request a preapplication
package. A small number of grants are
awarded through requests for proposals
(RFPs), sometimes as grant competitions.
https://www.
arc.gov/fundi
ng/ARCGrants
andContracts.
asp
Application
process,
Grant
program
O&M, Other,
Outreach
Awardee must contribute
matching funds to extent
practical.
50% of the
cost of the
project
Varies by year; visit
https://www.arc.gov/publications/
BudgetDocuments.asp for
information on funding levels.
Targets economically distressed
counties in the Appalachian Region.
Must address at least one of the five
goals identified by ARC. Grant
recipient must contribute matching
funds to the extent it is able to do so.
AL, GA,
KY, MD,
MS, NY,
NC, OH,
PA, SC,
TN, VA,
WV
Aquatic
Ecosystem
Restoration
U.S. Army Corps
of Engineers
(USACE)
Public-
private
partner
ship
Federal
The U.S. Army Corps of Engineers (USACE)
can carry out aquatic ecosystem restoration
and protection projects. A project is adopted
for construction only after a detailed
investigation determines that the project will
improve the quality of the environment and
is in the best interest of the public. (The
website provided is an example from one
USACE district.)
Formal assurance in the form of a Project
Partnership Agreement must be executed
with the project sponsor. Section 206 project
requests should be directed to (309) 794-
5704 or email
customeroutreach@usace.army.mil.
http://www.
mvr.usace.ar
my.mil/Busin
ess-With-
Us/Outreach-
Customer-
Service/Ecosy
stem-
Restoration/S
ection-206/
Long-term
program
Capital, Other
All design and
construction costs are
cost shared 65% Federal
and 35% non-Federal.
$10,000,000 (federal cost limit).
The initial study is 100% federally
funded up to $100,000. All
planning costs after the first
$100,000 are cost shared 50/50.
Projects generally include
manipulation of the hydrology in and
along bodies of water, including
wetlands and riparian areas. An
ecosystem restoration project under
Section 206 can be initiated upon
receipt of a request from a
prospective project sponsor.
National
Arizona Clean
Water State
Revolving Fund
(CWSRF)
Water
Infrastructure
Finance
Authority of
Arizona (WIFA)
Loan
State
Eligible projects include construction,
expansion, and upgrades to wastewater
treatment plants, upgrade or replacement of
failing decentralized wastewater systems,
septic to sewer, reclaimed water and reuse
and stormwater management including
green infrastructure, Low Impact
Development and flood control. New project
eligibilities include: watershed management,
integrated water resources planning,
resilience planning, forest restoration,
riparian improvements, stream channel
restoration and streambank stabilization.
Applications are accepted at any time. Apply
online at https://applicant.azwifa.gov/.
http://www.a
zwifa.gov/loa
n-
programs/?c
w
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Must have a Fiscal
Sustainability Plan.
Repayment of loans
provides funding for
future projects.
State fiscal year 2018 total
available funds: $120 million.
Eligible borrowers include: public
jurisdictions such as cities, towns,
special districts etc. Federally-owned
systems are not eligible.
AZ
2
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Arizona
Drinking Water
Revolving Fund
(DWRF)
Water
Infrastructure
Finance
Authority
(WIFA)
Loan
State
States can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents are available at:
http://www.azwifa.gov/loan-
programs/?dw#HA-DW. Applicants must
submit a Priority Project List (PPL)
application through WIFA's electronic
application system. The PPL serves as a guide
for funding decisions by the WIFA Board of
Directors and does not determine the order
in which projects are funded. AZ uses a
portion of its set-aside to conduct source
water assessments.
http://www.a
zwifa.gov/loa
n-
programs/?d
w#HA-DW
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs. Eligible projects
can be found at:
http://www.azwifa.gov/lo
an-programs/?dw#HA-
DW.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, land
acquisition, and more. Ineligible
activities: dam rehab, O&M, projects
serving growth, etc.
AZ
Arkansas Clean
Water State
Revolving Fund
(CWSRF)
Arkansas
Natural
Resources
Commission
(ANRC)
Loan
State
Arkansas Clean Water State Revolving Fund
(CWSRF) provides low interest loans for
wastewater programs. Objectives are to
hasten wastewater treatment facility
construction in order to meet the
enforceable requirements of the Clean
Water Act (CWA), emphasize non-point
source pollution control and the protection
of estuaries, and facilitate the establishment
of permanent institutions in each State that
would provide continuing sources of
financing needed to maintain water quality.
Projects must apply to be on the annual
priority list in the State's Intended Use Plan
(IUP). Applications can be found online.
Contact state office for more information.
https://www.
anrc.arkansas
.gov/divisions
/water-
resources-
development
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Arkansas leverages
periodically to increase
the funds available for
assistance. Arkansas has
no plans to leverage the
Clean Water program in
State Fiscal Year 2020.
Loan repayments provide
a continuing source of
funds for additional
projects.
$5,000
Varies
Funds are used for new or existing
systems; generally funds are for
capital improvement projects.
AR
Arkansas
Drinking Water
State
Revolving Fund
(DWRSF)
Program
Arkansas
Natural
Resource
Commission
(ANRC), the
Arkansas
Department of
Health
Engineering,
and the
Arkansas
Development
Finance
Authority
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. Arkansas uses a portion of its set-
aside to implement a statewide source water
assessment/protection program, conduct
source water Harmful Algal Bloom (HAB)
monitoring, update its Source Water
Assessment and Protection Plan, and provide
public outreach efforts on the importance of
source water protection.
Funding applications are received and
processed through ANRC's website via the
ANRC Funding Application, available at:
https://www.anrc.arkansas.gov/divisions/wa
ter-resources-development/waste-and-
wastewater-funding-applications. Arkansas
uses a portion of its set-aside to implement a
statewide source water
assessment/protection program, conduct
source water Harmful Algal Bloom (HAB)
monitoring, update its Source Water
Assessment and Protection Plan, and provide
public outreach efforts on the importance of
source water protection.
https://www.
anrc.arkansas
.gov/divisions
/water-
resources-
development
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
AR
Arkansas
Water
Development
Division
Programs
Arkansas
Natural
Resources
Commission
(ANRC)
Grant
State
Arkansas Natural Resources Commission
(ANRC) has available funding for water and
wastewater projects from both State and
Federal programs. Each of these programs
has its own requirements and limitations.
Each applicant fills out a general ANRC
application form and ANRC staff will
determine which program best fits the
community's needs. Applications are
accepted on a rolling basis; check the
website for detailed instructions on how to
begin the application process.
http://anrc.ar
k.org/division
s/water-
resources-
development
/
Application
process,
Grant
program,
Non-
competitive
process
Capital
Has funded
projects
starting at
$5,000.
Has funded projects up to
$50,000,000.
Non-entitlement cities and counties,
and funding projects must certify
that at least 51% of the households
served are low or moderate income
based upon the HUB section 8
income limits. Generally funds for
capital improvement not
maintenance.
AR
Arkansas
Water
Development
Division
Programs
Arkansas
Natural
Resources
Commission
(ANRC)
Loan
State
ANRC has available funding for water and
wastewater projects from both State and
Federal programs. Each of these programs
has its own requirements and limitations.
These funds GO Bond, Water Development
Fund, and Water, Sewer, and Solid Waste
Fund.
Each applicant fills out a general ANRC
application form and ANRC staff will
determine which program best fits the
community's needs. Applications are
accepted on a rolling basis; check the
website for detailed instructions on how to
begin the application process.
http://anrc.ar
k.org/division
s/water-
resources-
development
/
Application
process, Fund
allocation to
states and
localities,
Loan program
Capital, Other
Low interest loans.
$5,000
ANRC has funded projects up to
$50,000,000.
Eligible entities: Cities, Towns,
Counties, Rural Development
Authorities, Public Facilities Boards,
Water Associations, Improvement
Districts, Regional Distribution
Districts, Levee and Drainage
Districts, Conservation Districts,
Regional Districts.
AR
3
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Ayrshire
Foundation:
Grant
Ayrshire
Foundation
Grant
Private
The Ayrshire Foundation provides grants to
501(c)(3) nonprofit organizations that
embrace people, infrastructure, values,
practices and policies for organizational
success. The Foundation has focused its
funding in five areas: Opportunities for
Youth; Science and the Environment;
Healthcare; Services for the Elderly and
Disabled; and Community Culture.
Preference is given to organizations located
in Southern California and Petoskey/Harbor
Springs, Michigan. However, the Foundation
welcomes inquiries from other locations.
Applications are submitted online and are
reviewed at semi-annual board meetings.
Applications are due by March 15 for
consideration during the May/June meeting,
and September 15 for consideration during
the October meeting. The Foundation will
respond with a request for a proposal for
applications selected during the board
meetings. Application instructions are
available at:
http://ayrshirefoundation.org/apply-for-a-
grant/overview/.
http://ayrshir
efoundation.
org/
Application
process,
Grant
program
Other,
Outreach
Grants can be leveraged
to attract other funds and
projects. Considers
matching and multi-year
grants.
None
$1 million
Must be a 502(c) 3 non-profit.
S.California and Petoskey/Harbor
Springs Michigan Organizations are
given preference.
CA
Beaches
Environmental
Assessment
and Coastal
Health
(BEACH) Act
Grants
U.S.
Environmental
Protection
Agency (EPA)
Grant
Federal
The EPA's Beaches Environmental provides
formula grants to eligible states, territories,
and tribes to support microbiological testing
and monitoring of coastal recreation waters,
including the Great Lakes, that are adjacent
to beaches or similar points of access used
by the public. BEACH Act grants also provide
support for development and
implementation of programs to notify the
public of the potential exposure to disease-
causing microorganisms in coastal recreation
waters.
Contact State, Territory, or Tribe BEACH
Program Coordinator. Information found at
https://ofmpub.epa.gov/apex/beacon2/f?p=
beacon2:50:15990463087148
https://www.
epa.gov/beac
h-
tech/beach-
grants
Application
process, Fund
allocation to
states and
localities,
Grant
program,
Long-term
program
Other
$9.4 million total for FY17. Grants
range from $50,000 to $445,000.
Eligible Coastal and Great Lakes
states, territories, and tribes. Three
factors impact grant: Length of beach
season, number of miles of
shorelines, populations of coastal
counties.
AL, AK,
American
Samoa,
CA, CT,
DE, FL,
GA,
Guam, HI,
IL, IN, LA,
ME, MD,
MA, Ml,
MS,
Northern
Mariana
Islands,
NH, NJ,
NY, NC,
OH, OR,
PA,
Puerto
Rico, Rl,
SC, TX,
VA, Virgin
Islands,
WA, Wl
Better Utilizing
Investments to
Leverage
Development
(BUILD)
Transportation
Discretionary
Grants
program
U.S.
Department of
Transportation
(DOT)
Grant
Federal
Program replaced the Transportation
Investment Generating Economic Recovery
(TIGER) grant program. BUILD Transportation
grants are for investments in surface
transportation infrastructure and are to be
awarded on a competitive basis for projects
that will have a significant local or regional
impact. BUILD funding can support roads,
bridges, transit, rail, ports or inter-modal
transportation.
Applications must be submitted to
Grants.gov. Applicants are encouraged to
provide quantitative information, including
baseline information that demonstrates how
the project will reduce stormwater runoff.
https://www.
transportatio
n.gov/BUILDg
rants
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Grant
program
Capital
$25,000,000; no more than
$150,000,000 can be awarded to a
single state.
Projects should have a significant
local or regional impact. Eligible
entities: state, local, and tribal
governments, metro planning
organizations, port authorities, other
political subdivisions.
National
4
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Border
Environment
Infrastructure
Fund (BEIF)
North American
Development
Bank (NADB)
Grant
Federal
NADB established the Border Environment
Infrastructure Fund (BEIF) to administer
grant resources provided by EPA for the
implementation of high-priority municipal
drinking water and wastewater
infrastructure projects in the U.S.-Mexico
border region. Only water and wastewater
infrastructure projects located within 100
kilometers (62 miles) of the U.S.-Mexico
border will be considered for funding. The
objective of the BEIF program is to make
infrastructure projects affordable for
communities throughout the U.S.-Mexico
border region by combining grant funds with
loans and other forms of financing.
When funding becomes available, EPA
Region 6 (serving Texas and New Mexico)
and Region 9 (serving Arizona and California)
issue a solicitation that identifies the
timeframe for submitting an application,
documents that need to accompany the
application, ranking criteria, and information
on the funding process. See
http://www.becc.org/funding-
programs/infrastructure-funding/beif#/tabl
for details.
http://nadba
nk.org/progra
ms/beif.asp
Application
process,
Grant
program
Capital
None
$8 million. Funding levels vary by
annual congressional
appropriation; grant amounts are
based on a financial analysis of the
project, utility and community that
takes into consideration eligible
projects costs and the availability
of other funding.
Only water and wastewater
infrastructure projects located within
100 km of the U.S.-Mexico border
will be considered for funding.
TX, NM,
AZ, CA
Bring Back the
Natives
National Fish
and Wildlife
Foundation
(NFWF)
Grant
Private
Support for this program is provided by the
U.S. Fish and Wildlife Service, the U.S. Forest
Service, Bass Pro Shops and the Brunswick
Foundation. Invests in conservation activities
that restore, protect and enhance native
populations of sensitive or listed fish species
across the United States, especially in areas
on or adjacent to federal agency lands. This
funding opportunity also provides grants to
implement the goals of the National Fish
Habitat Action Plan.
All application materials must be submitted
online through NFWF's Easy grants system.
See
http://www.nfwf.org/bbn/Pages/2017rfp.as
px for more information.
http://www.n
fwf.org/bbn/
Pages/home,
aspx
Application
process,
Grant
program,
Long-term
program
Capital, O&M,
Other
Applicants must provide
at least $1 in matching
non-federal funds for
every $1 of NFWF grant
funds requested. Support
of program from: U.S. Fish
and Wildlife Service, the
U.S. Forest Service, Bass
Pro Shops and the
Brunswick Foundation.
$25,000
Up to $1,000,000 in grant funds is
available. Grant awards generally
range in size from $50,000 to
$100,000, although grants greater
than $100,000 will be considered
on a case by case basis. In 2017, 15
grants totaling $1 million were
awarded.
Applicants can include: Local, state,
federal, and tribal government
agencies, special districts, non-profit
organizations, schools, and
universities.
National
Bullitt
Foundation:
Grant
Bullitt
Foundation
Grant
Private
Focuses on infrastructure design that
optimizes efficiencies among land use,
transportation, energy, water, and waste
systems; operates at a cost effective scale;
enhances natural systems; reduces carbon
emissions; and stores carbon. It advances
green infrastructure alternatives to grey
infrastructure. The Foundation also seeks to
develop conservation finance mechanisms,
metrics, and other needed tools to
encourage protection and restoration of
ecosystem service values related to urban,
agricultural, forest, and open space lands.
The Foundation funds 501(c)(3) nonprofit
organizations, Municipal Corporations, Public
Agencies, and Tribal Governments.
Applications are submitted through the
Online Grantee Portal. Application
instructions are available at:
http://www.bullitt.org/grants/grantmaking-
process/. Applications are due by March 15
for the Fall and September 15 for Spring.
"Sunset" grant operations in 2024.
http://www.b
ullitt.org/
Application
process,
Grant
program,
Long-term
program
Other,
Outreach
None
$120,000
Projects must be located in the
"Emerald Corridor" from Portland,
Oregon to Vancouver, British
Columbia. Must be a 501(c) 3
nonprofit. Final report must be in
before eligible for new grant.
WA, OR
5
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
California
Drinking Water
State
Revolving Fund
(DWSRF)
California State
Water
Resources
Control Board
(SWRCB),
Division of
Financial
Assistance (DFA)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents are available at:
https://www.waterboards.ca.gov/drinking_w
ater/services/funding/SRF.html under the
"How Do 1 Apply?" section tab. A complete
application package includes: an
Environmental Package, a Technical Package,
a Financial Security Package. CA's SWP
program provides loans to PWSs for the
purchase of land or conservation easements.
PWSs may only purchase land or a
conservation easement from willing parties.
The purchase must be for the purposes of
protecting the system's source water and
ensuring compliance with national drinking
water regulations.
https://www.
waterboards.
ca.gov/drinki
ng_water/ser
vices/funding
/SRF.html
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
CA
California
Infrastructure
State
Revolving Fund
(ISRF)
California
Infrastructure
and Economic
Development
Bank (IBank)
Loan
State
Provides financing to public agencies and
nonprofit corporations sponsored by public
agencies for a wide variety of infrastructure
and economic development projects
(excluding housing).
Application materials are located on the
website. Potential applicants are encouraged
to call before applying.
http://www.i
bank.ca.gov/i
nfrastructure-
state-
revolving-
fund-isrf-
program/
Application
process, Loan
program,
Long-term
program
Capital, Other
May serve as matching
funds for other projects.
$50,000
$25,000,000
Include, but are not limited to any
subdivision of a local government,
including cities, counties, special
districts, assessment districts, joint
powers authorities and nonprofit
corporations (as deemed eligible).
Max term 30 years.
CA
Chesapeake
Bay Program
(CBP) Grants
U.S.
Environmental
Protection
Agency (EPA)
Grant
Federal
The EPA's Chesapeake Bay Program awards
grants to reduce and prevent pollution and
to improve the living resources in the
Chesapeake Bay. Grants are awarded for
implementation projects, as well as for
research, monitoring, and other related
activities.
For competitive awards, proposals are
typically due within 45 days from the date a
Request for Proposal (RFP) is issued. RFPs
are issued throughout the year and CBP
typically issues 1-5 RFPs per year. The rest of
the awards are issued non-competitively to
signatory jurisdictions as determined by
Section 117 of the Clean Water Act. Visit
http://www.chesapeakebay.net/rfps to view
RFPs and
https://www.epa.gov/sites/production/files/
2016-
01/documents/2016cbpograntguidance.pdf
to view EPA's Chesapeake Bay Program
Office Grant Guidance.
https://www.
epa.gov/resto
ration-
chesapeake-
bay
Fund
allocation to
states and
localities,
Grant
program
Other,
Outreach
Grants to the extent
possible should target
opportunities for public-
private partnerships that
increase leveraged
resources.
$15,000 (in
2014)
Varies depending on the specific
funding opportunity.
Eligible entities: Nonprofits, state,
and local governments, colleges,
universities, and interstate agencies.
DE, MD,
NY, PA,
VA, WV
Chesapeake
Bay
Stewardship
Fund:
Chesapeake
Bay Small
Watersheds
Grant Program
National Fish
and Wildlife
Foundation
(NFWF)
Grant
Private
Provides grants to organizations and local
governments to protect and improve
watersheds in the Chesapeake Bay basin,
while building citizen-based resource
stewardship. Supports protection and
restoration actions that contribute to
restoring healthy waters, habitat and living
resources of the Chesapeake Bay ecosystem.
All application materials must be submitted
online through NFWF's Easy grants system,
(www .nfwf.org/easy grants.)
https://www.
chesapeakeb
ay.net/what/
grants/small_
watershed_gr
ants
Application
process,
Grant
program
Other,
Outreach
Grants have been used to
leverage more than $27
million in support of 626
projects. Grantees must
have matching
contributions equal to at
least 25% of total project
costs.
$20,000
Grants are between $20,000 and
$200,000.
For organizations and local
governments that work on
community-based projects to
improve condition of local
watershed.
DE, MD,
NY, PA,
VA, WV
Chesapeake
Bay
Stewardship
Fund:
Innovative
Nutrient and
Sediment
Reduction
Program
National Fish
and Wildlife
Foundation
(NFWF)
Grant
Private
Partnership with EPA and Chesapeake Bay
Program. The overall goal for the Program is
to expand the collective knowledge on the
most innovative, sustainable and cost-
effective strategies - including market-based
approaches - for reducing excess nutrient
loads within specific tributaries to the
Chesapeake Bay.
All application materials must be submitted
online through NFWF's Easy grants system,
(www .nfwf.org/easy grants.)
https://www.
nfwf.org/ches
apeake/Pages
/2019-insr-
rfp.aspx
Application
process,
Competitive
process,
Grant
program,
Long-term
program
Capital,
Other,
Outreach
Require non-federal
matching equal or greater
than grant. Can be used to
leverage other funds.
$200,000
Up to $500,000.
Project must occur entirely in the
Chesapeake Bay Watershed. Projects
to restore water quality and habitat
in Chesapeake Bay.
DE, MD,
NY, PA,
VA, WV
6
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Clean Water
Act Indian Set-
Aside (CWISA)
Grant Program
U.S.
Environmental
Protection
Agency (EPA)
Grant
Federal
Provides assistance to Indian tribes and
Alaska Native Villages for the planning,
design, and construction of wastewater
treatment systems. Eligible projects include,
but are not limited to, interceptor sewers,
wastewater treatment facilities,
infiltration/inflow correction, collector
sewers, major sewer system rehabilitation,
and correction of combined sewer
overflows. Funding for the Set-Asides is from
the Clean Water Act State Revolving Fund
(CWSRF).
To be considered for CWISA program
funding, tribes must identify their
wastewater needs to the Indian Health
Service (IHS) Sanitation Deficiency System.
EPA uses the IHS Sanitation Deficiency
System priority lists to identify and select
projects for CWISA program funding. Contact
your IHS area office and EPA regional office
for more information
(https://www.epa.gov/sites/production/files
/2015-03/documents/cwisa-tribal-faq-
highres.pdf).
https://www.
epa.gov/small
-and-rural-
wastewater-
systems/clea
n-water-
indian-set-
aside-
program
Application
process,
Grant
program
Capital, Other
Funding used for
wastewater
infrastructure: Planning,
design, and construction
of wastewater collection
and treatment systems.
Projects are awarded
based on Sanitation
Deficiency System.
Funding varies by IHS area. Total
funding for all IHS areas is
$28,000,000.
Must be a federally recognized tribe,
projects must be related to
wastewater infrastructure.
National
Clean Water
Fund Program
(CWFP)
Wisconsin
Department of
Natural
Resources
(DNR)
Loan
State
Provides subsidized (low-interest rate) loans
to municipalities for wastewater and
stormwater infrastructure projects to
protect water quality and public health. It
includes projects for compliance with a
municipality's Wisconsin Pollutant Discharge
Elimination System (WPDES) permit. Some
municipalities may also be eligible for
funding in the form of principal (loan)
forgiveness.
Application guidance and considerations are
available under the How to Apply tab on the
webpage at
http://dnr.wi.gOv/Aid/EIF.html#tabx3. Pre-
Application Deadline: All notices of Intents to
Apply (ITAs) & Priority Evaluations and
Ranking Formulas (PERFs) must be submitted
online by October 31st for the following
state fiscal year funding cycle.
http://dnr.wi.
gov/Aid/EIF.h
tml
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Repayment of loans
provides funding for
future projects.
Eligible entities include municipalities
or local governments. Eligible
projects must be wastewater or
stormwater infrastructure based.
Wl
Clean Water
State
Revolving Fund
Program
(CWSRF)
California
Environmental
Protection
Agency - State
Water
Resources
Control Board
(SWRCB)
Loan
State
Offers low cost financing for a wide variety
of water quality projects.
Applications are accepted on a continuous
basis. An online application can be
completed and submitted at:
https://faast.waterboards.ca.gov
http://www.
waterboards.
ca.gov/water
Jssues/progr
ams/grantsj
oans/srf/inde
x.shtml
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Amount and timing of
additional state leveraging
over and above the
current limit would
continue to depend on
total costs of projects
financed and approval
timing. Loan repayments
provide a continuing
source of funds for
additional projects.
Total annual program average is
$500,000,000; program can fund
projects over $100,000,000.
Eligible applicants include: City,
Town, district, or public body created
by law, Native American Tribal
organization, approved management
agency under section 208 CWA, and
501(c)3 and National Estuary
Programs.
CA
Coastal
Pollutant
Remediation
Grant Program
Massachusetts
Office of Coastal
Zone
Management
Grant
State
Provides funding to municipalities located
within the Massachusetts coastal watershed
for projects to address stormwater runoff
and boat-waste from commercial vessels.
Eligible projects include assessment of
stormwater pollution within the watershed,
prioritization of locations for remediation,
and design, permitting and construction of
stormwater best management practices and
commercial boat-waste pump-outs.
The requests for responses (RFR) is typically
released in the spring. Interested applicants
should check the CPR website to see when
the RFR will be released or e-mail the
contact for more information.
www.mass.go
v/czm/cpr
Application
process,
Grant
program,
Long-term
program
Capital, Other
None
$175,000
Municipal program/project that
characterizes and treats stormwater
runoff from highways, improved and
protects coastal water quality habitat
and recreational use, and removes
waters from the MADEP integrated
list of waters.
MA
Coastal
Resilience
Grants
Program
National
Oceanic and
Atmospheric
Administration
(NOAA)
Grant
Federal
This competitive grant program funds
projects that are helping coastal
communities and ecosystems prepare for
and recover from extreme weather events,
climate hazards, and changing ocean
conditions.
All project proposals undergo a rigorous
merit review and selection process by a
panel of subject matter experts from across
the United States that include
representatives of government, academia,
and private industry.
https://coast.
noaa.gov/resi
lience-grant/
Application
process,
Competitive
process,
Grant
program
Capital, O&M
Requires a non-Federal
dollar match.
Since 2015, NOAA has funded 48
projects through $35.8 million in
federal funds.
Projects should save lives, protect
property, reduce damage to
infrastructure, and benefit
ecosystems and the economy.
Common project aspects include
natural and nature-based
infrastructure, post-disaster
recovery, and assessing
risk/prioritizing action.
National
7
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Colorado
Drinking Water
Revolving Fund
(DWRF)
Colorado
Department of
Public Health
and
Environment
(CDPHE)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents are available at:
https://www.colorado.gov/pacific/cdphe/wa
ter-quality-low-interest-loan-application.
Applicants must first complete and submit a
prequalification form and attend a
preapplication meeting before submitting a
formal loan application. CO uses a portion of
its set-aside to provide technical expertise
and assistance to local stakeholders for
developing and implementing source water
protection plans.
https://www.
colorado.gov/
pacific/cdphe
/wq-low-
interest-loans
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, land
acquisition, and more.
CO
Colorado
Water Quality
Grants
Colorado
Department of
Public Health
and
Environment
(CDPHE)
Grant
State
Grant programs are available for: planning
and design and engineering, small
community water and wastewater projects,
and water, wastewater, and stormwater
projects. Water and wastewater grants are
not currently available.
Applicants must complete an Eligibility
Survey, Pre-Qualification Form, and Pre-
Application Meeting Form prior to applying.
Application deadlines are the 15 of January,
February, April, June, August, October, and
November.
https://www.
colorado.gov/
pacific/cdphe
/wq-grants
Application
process,
Grant
program
Capital, O&M,
Other
Matching required for
some grants.
None
Funding is dependent on federal
and state allocations and priorities.
Small communities that apply for
design and engineering funds for
State Revolving Fund (SRF)
requirements require a 20% match.
CO
Colorado's
Water
Pollution
Control
Revolving Fund
(WPCRF) Loan
Program
Colorado
Department of
Public Health
and
Environment
(CDPHE)
Loan
State
The Water Pollution Control Revolving Fund
(WPCRF) provides low interest loans to
governmental agencies for construction of
wastewater infrastructure projects. This is
known as Colorado's Clean Water State
Revolving Fund (CWSRF).
An applicant must complete an Eligibility
Survey, Pre-Qualification Form, and Pre-
Application Meeting Form prior to applying.
Loan application deadlines are the 15 of
January, February, April, June, August,
October, and November.
https://www.
colorado.gov/
pacific/cdphe
/wq-general-
srf-
information
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Applicants may qualify for
a planning or
design/engineering grant.
Loan repayments provide
a continuing source of
funds for additional
projects.
None
Direct loans are for projects up to
$2.5 million. Leveraged loans are
for governmental entity projects
greater than $2.5 million.
Must be a City, Town, County, water
sanitation district, water district, or
private nonprofit public water
system.
CO
Communities
Unlimited, Inc.
Water/Waste
water Loans
Communities
Unlimited, Inc;
Rural
Community
Assistance
Partnership
(RCAP)
Loan
Private
Offers loans with terms up to 15 years for
small, rural community water/wastewater
projects.
Complete application form:
https://www.communitiesu.org/images/CU.
W.WW.LoanApplicationForm.pd. fEmail
application to: info@CommunitiesU.org.
https://www.
communities
u.org/index.p
hp/How-We-
Help/water-
waste-water-
loans.html
Application
process, Loan
program,
Long-term
program
Capital,
Compliance,
O&M, Other
None
In 2017, Communities Unlimited's
loans totaled over $2.6 million.
Small, rural community water and
wastewater projects that are needed
to make repairs and improvements
to maintain uninterrupted supply of
safe drinking water and wastewater
disposal to customers. Must be able
to repay loan with system revenues.
AR
Community
Assistance
Program (CAP)
North American
Development
Bank (NADB)
Grant
Federal
Community Assistance Program (CAP) grants
are available for public projects in all
environmental sectors eligible for North
American Development Bank (NADB)
financing. Priority will be given to drinking
water, wastewater, water conservation and
solid waste infrastructure. The funding,
construction, and operation of a proposed
project must be completely independent and
not depend on any other pending
investment.
Application can be found online. The project
must be located within 100 km (62 miles)
north of the international boundary in the
four U.S. states of Texas, New Mexico,
Arizona and California. Projects that receive
a grant through the Border Environment
Infrastructure Fund (BEIF) are not eligible for
CAP funding. Eligible projects must be
completely independent and not depend on
any other pending investment.
http://www.n
adbank.org/~
nadborg/inde
x.php?acc=co
ntest&tpl=ca
P
Application
process,
Grant
program
Capital, O&M,
Other
Designed to serve low-
income communities in
the border region. The
project sponsor must
contribute at least 10% of
the total project cost.
Projects may receive a CAP grant
for up to $500,000.
Project must remedy an
environmental and/or human health
problem in US Mexico border region.
Project sponsor must have legal
authority to develop, must be
capable of meeting criteria
certification by the Board of
Directors.
TX, NM,
AZ, CA
Community
Development
Block Grant
(CDBG) -
Disaster
Recovery (DR)
Program
U.S.
Department of
Housing and
Urban
Development
(HUD)
Grant
Federal
Provides flexible grants to help cities,
counties, and States recover from
Presidential^ declared disasters, especially
in low-income areas, subject to availability of
supplemental appropriations. Funds MUST
be used for disaster relief, long-term
recovery, and restoration of infrastructure,
housing, and economic revitalization.
HUD allocates funds based on unmet
recovery needs. Contact a local office to see
if community is eligible.
https://www.hud.gov/program_offices/field
_policy_mgt/localoffices
https://www.
hudexchange.
info/program
s/cdbg-dr/
Application
process, Fund
allocation to
states and
localities,
Grant
program,
Long-term
program
Capital, O&M,
Other
When the President declares a
major disaster, Congress may
appropriate funds to the
Department of Housing and Urban
Development (HUD) when there
are significant unmet needs for
long-term recovery.
HUD will notify eligible States, cities
and counties if they are eligible to
receive CDBG-DR grants. Must
submit an action plan, if approved
grantee must sign a grant agreement.
National
8
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Community
Development
Block Grant
Program
(CDBG)
U.S.
Department of
Housing and
Urban
Development
(HUD)
Grant
Federal
CDBG funds may be utilized to address a
wide variety of community needs, including
construction or renovation of various
infrastructure projects such as water,
wastewater and solid waste facilities, streets,
and flood control projects. The funds must
be used for activities that either benefit low-
and moderate-income persons or address
community development needs that have a
particular urgency.
Links to program areas and their application
requirements are available online.
http://portal.
hud.gov/hud
portal/HUDPs
rc=/program_
offices/comm
_planning/co
mmunitydeve
lopment/prog
rams
Grant
program,
Long-term
program
Capital, Other
Eligible activities must meet one of
the national objectives for the
program and not less than 70% of
CDBG funds must be for activities
that benefit low and moderate-
income persons.
National
Community
Development
Block Grant
Program
(CDBG) -
General
Purpose Grant
Fund Planning
- Only
Activities (WA
State)
State of
Washington -
Department of
Commerce
Grant
State
Pending HUD CDBG Funding, the
Washington State CDBG program sets aside
limited funds for the following specialty
grants to assist specific types of projects:
Economic Opportunity, Housing
Enhancement, and Public Services.
Applications must be completed and
submitted by June 3, 2020. Application
information for Year 2020 will be available
on the webpage during March 2020. Projects
must principally benefit low- and moderate-
income residents in non-entitlement cities
and counties (cities or towns with fewer than
50,000 people; counties with fewer than
200,000 people).
https://www.
commerce.w
a.gov/serving
communities/
community-
development-
block-grants/
Application
process, Fund
allocation to
states and
localities,
Grant
program
Capital, Other
$24,000 for a single jurisdiction
CDBG funding can address: sewer,
water, streets, or other
infrastructure; community facilities;
economic development; housing
rehabilitation and infrastructure;
planning; and public services.
WA
Community
Development
Block Grant
Program
(CDBG) -
General
Purpose Grant
(WA State)
State of
Washington -
Department of
Commerce
Grant
State
Pending HUD CDBG Funding, the
Washington State CDBG program sets aside
limited funds for the following specialty
grants to assist specific types of projects:
Economic Opportunity, Housing
Enhancement, and Public Services.
Eligible applicants must submit their
applications by June 3, 2020. Projects must
principally benefit low-to moderate income
people in non-entitlement cities and
counties (cities or towns with fewer than
50,000 people; counties with fewer than
200,000 people).
https://www.
commerce.w
a.gov/serving
communities/
community-
development-
block-grants/
Application
process, Fund
allocation to
states and
localities,
Grant
program
Capital, O&M,
Other
$750,000 (construction and
acquisition projects); $500,000
(local housing rehabilitation
programs); $250,000 (local
microenterprise assistance
programs); and $24,000 (planning-
only activities).
Eligible projects: final design and
construction of wastewater, drinking
water, side connections, stormwater,
streets, and community facility
projects; Infrastructure for economic
development or affordable housing;
and specific planning activities.
WA
Community
Engagement
Mini Grant
Chesapeake Bay
Trust (CBT)
Grant
Private
Designed to engage Maryland residents in
activities that enhance communities, engage
residents, and improve natural resources.
Applicants accepted starting June of each
year, on a rolling basis. Details available at
https://www.grantrequest.com/Login.aspxPR
eturnUrl=%2fapplication.aspx%3fSA%3dSNA
%26FID%3d35004%26sid%3dl520&SA=SNA
&FID=35004&sid=1520. Must have received
three or fewer grants from Chesapeake Bay
Trust (CBT) in the past.
https://cbtrus
t.org/grants/c
ommunity-
engagement/
Application
process,
Grant
program
Other,
Outreach
None
$5,000
Maryland nonprofit organizations,
community associations, faith based
organizations, etc. Examples include:
Planting trees, installing rain gardens,
and stream cleanups. Enhance
communities, engage residents, and
improve natural resources.
MD
Community
Facilities Direct
Loan & Grant
Program
U.S.
Department of
Agriculture
(USDA) Rural
Utility Service
(RUS)
Loan
Federal
Provides funding for clean and reliable
drinking water systems, sanitary sewage
disposal, sanitary solid waste disposal, and
stormwater drainage to households and
businesses in eligible rural areas.
Contact local office to discuss specific
projects. Applications for this program are
accepted year round. Program resources are
available online (includes forms needed,
guidance, certifications). Request a Data
Universal Number System (DUNS) number
online if the organization doesn't already
have one. Register the organization with the
System for Award Management (SAM)
online. Apply online using RD Apply:
https://rdapply.usda.gov
https://www.
rd.usda.gov/p
rograms-
services/com
munity-
facilities-
direct-loan-
grant-
program
Application
process, Loan
program
Capital, Other
Low interest direct loans
and grants are available.
These may be combined
with commercial financing
to finance one project if
all eligibility and feasibility
requirements are met.
Eligible borrowers: public bodies,
community-based nonprofit
corporations, and federally-
recognized tribes. Funds are for
purchase, construction and/or
improvement of essential community
facilities, purchase equipment, and
pay related project costs.
National
9
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Community
Facilities Direct
Loan & Grant
Program
U.S.
Department of
Agriculture
(USDA) Rural
Utility Service
(RUS)
Grant
Federal
This program provides funding for clean and
reliable drinking water systems, sanitary
sewage disposal, sanitary solid waste
disposal, and stormwater drainage to
households and businesses in eligible rural
areas.
Contact local office to discuss your specific
project. Applications for this program are
accepted year round. Program resources are
available online (includes forms needed,
guidance, certifications). Request a Data
Universal Number System (DUNS) number
online if the organization doesn't already
have one. Register the organization with the
System for Award Management (SAM)
online. Apply online using RD Apply:
https://rdapply.usda.gov
https://www.
rd.usda.gov/p
rograms-
services/com
munity-
facilities-
direct-loan-
grant-
program
Application
process,
Grant
program,
Long-term
program
Capital
Low interest direct loans
and grants are available.
These may be combined
with commercial financing
to finance one project if
all eligibility and feasibility
requirements are met.
Eligible borrowers: public bodies,
community-based nonprofit
corporations, and federally-
recognized tribes. Funds are for
purchase, construction and/or
improvement of essential community
facilities, purchase equipment, and
pay related project costs.
National
Community-
Based
Restoration
Program -
Coastal and
Marine Habitat
Restoration
Grants
National
Oceanic and
Atmospheric
Administration
(NOAA)
Grant
Federal
The Community-based Restoration Program
solicits applications for restoration projects
that use a habitat-based approach to
promote productive and sustainable
fisheries, improve the recovery and
conservation of protected resources, and
promote healthy ecosystems and resilient
communities.
Projects will be funded through cooperative
agreements. Apply through Grants.gov.
Application resources are available at
http://www.habitat.noaa.gov/funding/coast
alrestoration.html.
https://www.
fisheries.noaa
.gov/grant/co
astal-and-
marine-
habitat-
restoration-
grants
Application
process,
Competitive
process,
Grant
program,
Long-term
program
Capital, Other
No matching requirement
but NOAA typically
leverages its federal
funding with matching
contributions and/or
partnerships from a broad
range of sources.
$6 million in funding is available
for selected projects in 2019
ranging from $100,000 to $4
million over a one- to three-year
project period.
Eligible applicants: Institutions of
higher education, nonprofits,
commercial organizations, U.S.
Territories, State, Local and tribal
governments.
National
Connecticut
Drinking Water
State
Revolving Fund
(DWSRF)
Connecticut
Department of
Public Health
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Funding applications and forms are available
at: https://portal.ct.gov/DPH/Drinking-
Water/DWS/Forms-and-Applications
Applications must include estimated project
costs, project descriptions, project location,
environmental considerations, and project
benefits. Projects are ranked based on a
point program.
https://portal
.ct.gov/DPH/
Drinking-
Water/DWS/
Drinking-
Water-State-
Revolving-
Fund-
Program
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more. Program funding places an
emphasis on providing loans to small
water systems and communities that
need it most.
CT
Connecticut's
Clean Water
Fund (CWF)
Connecticut
Department of
Energy and
Environmental
Protection
(DEEP)
Loan
State
State's environmental infrastructure
assistance program. The fund consists of five
accounts, of which the federal account is
designated as a qualifying State Revolving
Fund (SRF). The funds include Combined
Sewer Overflow (CSO), Nutrient (Nitrogen
and Phosphorus) Removal, Small
Community, Collection System
Improvement, and Management System
grants.
Funding under the Clean Water Fund (CWF)
is established based upon a priority rating
system with criteria regarding improvements
to water quality and the protection of public
health. Applications, forms, and checklists
can be accessed on website. Applications are
accepted all year round.
https://www.
ct.gov/deep/c
wp/view.asp?
a=2719&q=3
25576
Application
process,
Competitive
process, Loan
program
Capital, O&M,
Other
The Revenue Bond
Program is the leveraged
financing strategy
implemented by the
Connecticut SRF that
maximizes the financing
capacity of the respective
federal capitalization
grants.
None
Funding varies based on program.
Total funds authorized for FY19 is
$16,000,000.
For municipalities in Connecticut.
Eligibility requirements vary by
action, e.g., Permitting, CSO
Treatment Plant Projects, Road
Water Restoration, etc.
CT
10
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Conservation
Initiative
Grants (CIG)
Program
U.S.
Department of
Agriculture
(USDA) Natural
Resources
Conservation
Service (NRCS)
Grant
Federal
Competitive grant process to stimulate the
development and adoption of innovative
conservation approaches and technologies in
conjunction with agricultural production.
Includes a national and state competition.
Applicants must complete and submit an
application, which is then uploaded to
Workspace (the grants.gov electronic
submission interface). For national grants, A
CIG funding notice is announced each year.
Funds for single- or multi-year projects, not
to exceed three years, are awarded through
a nationwide competitive grants process.
Projects may be watershed-based, regional,
multi-state or nationwide in scope. The
natural resource concerns eligible for
funding through CIG are identified in the
funding announcement and may change
annually to focus on new and emerging, high
priority natural resource concerns. The CIG
state component emphasizes projects that
benefit a limited geographical area.
Participating states announce their funding
availability for CIG competitions through
their state NRCS offices.
https://www.
nrcs.usda.gov
/wps/portal/n
rcs/main/nati
onal/program
s/financial/cig
/
Application
process,
Competitive
process,
Grant
program
Grantees must match the
CIG investment at least
one-to-one.
$150,000
$2 million
All non-Federal entities and
individuals are eligible to apply. All
CIG projects must involve EQIP-
eligible producers.
Conservation
Partners
Programs
(CPP) Grant
National Fish
and Wildlife
Foundation
(NFWF) and U.S.
Department of
Agriculture's
Natural
Resources
Conservation
Services (NRCS)
Grant
Federal
Provides grants on a competitive basis to
support field biologists and other habitat
conservation professionals (ecologists,
foresters, range cons, etc.) working with
Natural Resources Conservation Service
(NRCS) field offices in providing technical
assistance to farmers, ranchers, foresters
and other private landowners to optimize
fish and wildlife habitat conservation on
private lands.
Applications can be submitted online.
Competitive proposals will be focused on
one of the nine priorities: Pacific Salmon,
Grassland Bird Habitat, Great Lakes,
Mississippi River Basin, and/or the Gulf Coast
Plain States Working Lands Conservation.
http://www.n
fwf.org/Cons
ervationPartn
ers
Application
process,
Competitive
process,
Grant
program,
Long-term
program
Other,
Outreach
Match of at least 1:1 non-
federal cash or in-kind is
required, and will be
considered in application
review.
$50,000
Approximately $5.1 million in NRCS
funds are available. Typical grant
awards will range from $50,000 to
$300,000. Projects may be funded
for up to three years from the
completion of a grant agreement.
Eligible applicants: nonprofit 501(c)
organizations, farmer and
commodity-led organizations,
educational institutions, tribal
governments, and state or local units
of governments. Cannot be used for
political support, to comply with legal
requirements.
National
Construction
Loan
Rural
Community
Assistance
Corporation
(RCAC)
Loan
Private
RCAC's loan fund is a financial source for
rural communities in the west.
Projects must be located in rural areas with
populations of 50,000 or less in RCAC's
service region.
Applications are located online. Eligible
applicants: Nonprofit organizations, public
agencies, tribes, and low-income rural
communities with a population of 50,000 or
less, or 10,000 or less if proposed permanent
financing is through U.S. Department of
Agriculture (USDA) Rural Development (RD).
http://www.r
cac.org/lendi
ng/environm
ental-loans/
Application
process, Loan
program
Capital, Other
Requires commitment
letter for permanent
financing. Term matches
construction period 1%
loan fee.
$3 million
Eligible projects: Water, wastewater,
solid waste and stormwater facilities
that primarily serve low-income rural
communities. Can include pre-
development costs.
Rural
Western
US
Cooperative
Funding
Program
South Florida
Water
Management
District
Grant
State
The District has provided funding to local
governments, special districts, utilities,
homeowners associations, water users and
other public and private organizations for
stormwater, alternative water supply and
water conservation projects that are
consistent with the District's core mission.
The Cooperative Funding Program combines
these funding programs into one
streamlined program to provide partnership
opportunities and financial incentives to
implement local projects that complement
regional flood control, restoration, water
quality and water supply efforts.
Program offered based on District allocation
of funding. The Application processes closed
on August 16, 2019.
http://www.s
fwmd.gov/co
opfunding
Application
process,
Grant
program
Capital
50% cost share for
projects with FLDEP.
Florida Legislature
approved $40 million in
statewide funding for
developed water supply
and water resource
development.
From Fiscal Years 1997 to 2016,
AWS projects totaling
approximately $1.5 billion in
construction costs received partial
funding from the South Florida
Water Management District.
Projects must be construction-ready
alternative water supply projects or
ready-to-implement water
conservation technology.
FL
11
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Cooperative
Watershed
Management
Program:
Phase 1
U.S.
Department of
the Interior
(DOI) - Bureau
of Reclamation
Grant
Federal
Provides financial assistance to locally led
watershed groups to encourage diverse
stakeholders to form local solutions to water
management needs. Through Phase 1, the
Bureau of Reclamation provides financial
assistance for the establishment and further
development of watershed groups. A
watershed group is a self-sustaining, non-
regulatory group that addresses water
availability and quality issues within the
relevant watershed, represents a diverse
group of stakeholders, and can promote the
sustainable use of water resources within
the watershed. As part of Phase 1, entities
may perform outreach to stakeholders and
develop bylaws and articles of incorporation,
a mission statement, watershed
management project concepts, and a
watershed restoration plan. Eligible
applicants include states, tribes, local and
special districts (e.g., irrigation and water
districts), local governmental entities,
nonprofit organizations, and established
watershed groups in the western United
States and capable of supporting the
sustainable use of water resources within
the watershed.
Information is available at
https://www.usbr.gov/watersmart/. Funding
Opportunity Announcements will be posted
at www.grants.gov.
https://www.
usbr.gov/wat
ersmart/cwm
p/index.html
Application
process,
Competitive
process,
Grant
program
Other
Cost-sharing financial
assistance to watershed
groups.
Up to $50,000 per year for a
period of up to two years with no
non-Federal cost-share required.
Must be a watershed group. Has
Phase 1 and Phase II requirements.
Phase 1: geographic area, critical
watershed needs, implementation
results.
Western
US
Cooperative
Watershed
Management
Program:
Phase II
U.S.
Department of
the Interior
(DOI) - Bureau
of Reclamation
Grant
Federal
Through the Cooperative Watershed
Management Program (CWMP), the Bureau
of Reclamation provides financial assistance
to locally led watershed groups to encourage
diverse stakeholders to form local solutions
to water management needs. Through Phase
II, the Bureau of Reclamation provides cost-
shared financial assistance to watershed
groups for the implementation of on-the-
ground watershed management projects
that address critical water supply needs,
water quality, and ecological resilience of the
watershed. Eligible applicants are
established watershed groups that represent
a diverse group of stakeholders, have
completed a watershed restoration plan, and
are capable of promoting the sustainable use
of waters resources. A watershed group is a
self-sustaining, non-regulatory group that
addresses water availability and quality
issues within the relevant watershed,
represent a diverse group of stakeholders,
and can promote the sustainable use of
water resources within the watershed.
Check the WaterSMART website at
https://www.usbr.gov/watersmart/ for
information. Funding Opportunity
Announcements will be posted at
www.grants.gov.
https://www.
usbr.gov/wat
ersmart/cwm
P
Application
process,
Competitive
process,
Grant
program,
Long-term
program
Capital
Phase II project,
applicants must
contribute at least 50%.
For Phase II Reclamation will
award up to $100,000 per project
over a two-year period.
Phase II: Benefits, restoration
planning, stakeholder support,
readiness to proceed, performance
measure, and DOI Priorities met.
Western
US
12
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Cumberland
Plateau
Stewardship
Fund
National Fish
and Wildlife
Foundation
(NFWF)
Public-
private
partner
ship
Federal
Dedicated to restoring native forests to
conditions that will improve associated
wildlife species and the health of freshwater
systems, while advancing strategies to
support working forests. Five Priority areas:
establishing shortleaf pine, enhancing
shortleaf pine ecosystem, restoring and
enhancing riparian forest and watersheds,
coordinating technical assistance, facilitating
conservation easements.
The 2018 application deadline was February
15, 2018. All application materials must be
submitted online through NFWF's Easy
grants system: www.nfwf.org/easygrants.
http://www.n
fwf.org/cumb
erland/Pages/
home.aspx
Application
process,
Competitive
process,
Grant
program,
Long-term
program
Other,
Outreach
Public-private partnership
with federal funding.
Requires a minimum of
1:1 non-federal match,
but larger match ratios
and matching fund
contributions from a
diversity of partners are
encouraged and will be
more competitive.
Grant awards will range from
$50,000 to $200,000, depending
on the overall scale of the project.
ri ujects within the Cumberland
Plateau in eastern Kentucky, central
Tennessee and northern Alabama
and Georgia are eligible.
AL, GA,
KY, TN
Cynthia and
George
Mitchell
Foundation:
Water Grant
Cynthia and
George Mitchell
Foundation
Grant
Private
Funds high-fflimpact projects in the State of
Texas at the nexus of environmental
protection, social equity, and economic
vibrancy administered by 501(c)(3) nonprofit
organizations. Current strategic grantmaking
programs focus on: Clean Energy; Galveston;
Land Conservation; Shale Sustainability;
Sustainability Education; and Water. The
Foundation believes that ensuring sufficient
and clean water for both economic growth
and the environment may be the most
significant and urgent concern facing Texas
in the next generation.
A Letter of Inquiry (LOI) is submitted online.
If the Foundation is interested in learning
more about the project the applicant will be
contacted to submit a grant application
proposal. The proposed project must align
with a specific foundation program, focus on
the state of Texas, and clearly demonstrate
how the project supports the relevant
foundation grantmaking strategy.
Application instructions are available at:
http://cgmf.Org/p/grantmaking.html
http://cgmf.o
rg/p/home.ht
ml
Application
process,
Competitive
process,
Grant
program
Other,
Outreach
None
Grants have ranged from $2,000 to
$300,000.
501(c)3 Nonprofits. Research must
contain explicit and practical policy
application. Does not fund
candidates, lobby in support of or
against legislation, does not fund
research, development,
commercialization or demonstration
of technology.
TX
David and
Lucile Packard
Foundation:
Conservation
and Science
Grant
David and Lucile
Packard
Foundation
Grant
Private
The Packard Foundation's Conservation and
Science Program invests in action and ideas
that conserve and restore ecosystems while
enhancing human well-being.
Project descriptions are submitted online. If
the Packard Foundation is interested in
learning more about the project the
applicant will be contacted to submit a grant
application proposal. Application instructions
are available at:
https://www.packard.org/grants-and-
investments/for-grantseekers/grant-
inquiry/Pprogram-
area=Conservation%20and%20Science
https://www.
Packard.org/g
rants-and-
investments/f
or-
grantseekers/
Application
process,
Grant
program
Other,
Outreach
None
Grants range from $50,000 to
$2,250,000.
Only for charitable, educational, or
scientific purposes, primarily from
tax-exempt charitable organizations.
Will not fund: individuals, lobbying
activities, conference fees and
tuition, religious organizations.
CA
David and
Lucile Packard
Foundation:
Impact
Investing
David and Lucile
Packard
Foundation
Loan
Private
While the Packard Foundation primarily
provides grants, mission investing can help
to drive social and environmental change by
seizing time-sensitive and higher-risk
opportunities, tackling large-scale projects,
attracting new sources of capital, and scaling
efforts for maximum impact. The Packard
Foundation has dedicated up to $180 million
of endowment for mission investments "
including loans and equity investments"
which serve as a flexible tool for non-profit
and for-profit organizations to tackle the
world's most pressing problems, sometimes
on a much larger scale than we are able to
do with grants alone.
Before submitting an application, review the
program areas on the website:
https://www.packard.org/grants-and-
investments/for-grantseekers/. If the project
aligns with a program's strategy, applicants
can submit a funding request to that
program.
https://www.
Packard.org/g
rants-and-
investments/
mission-
investing/
Application
process, Loan
program
Other,
Outreach
Can be used as a means to
attract new sources of
capital.
The Foundation has invested $760
million in 290 total investments
since its inception in 1964.
Lender must be reasonably confident
that the loan can be repaid. For
Social and Environmental Impact
projects.
CA
13
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Delaware
Drinking Water
State
Revolving Fund
(DWSRF)
Delaware
Department of
Health and
Social Services
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
For more information on the DWSRF
application process, contact the state
DWSRF program at 302-744-4817.
https://dhss.d
elaware.gov/
dhss/dph/hsp
/dwsrf.html
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
DE
Delaware
Water
Pollution
Control (Clean
Water) State
Revolving Fund
(WPCSRF)
Delaware
Department of
Natural
Resources and
Environmental
Control (DNREC)
Loan
State
Provides planning, engineering and financial
assistance in the form of low-interest loans,
as well as grants to eligible applicants that
request assistance to promote water quality
projects, including all types of non-point
source, watershed protection, restoration,
and estuary management projects, as well as
more traditional municipal wastewater
treatment projects.
Project Notice-Of-lntent (NOIs) are solicited
twice peryear, due by the end of January
and August. Applications can be accessed on
website.
https://dnrec.
alpha.delawar
e.gov/environ
mental-
finance/revol
ving-fund/
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan repayments provide
a continuing source of
funds for additional
projects.
None
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
Funds available for water quality
improvement projects completed by
municipalities, private organizations,
nonprofit organizations, and private
individuals.
DE
District of
Columbia
Clean Water
Construction
(CWC) Grant
Program
District of
Columbia
Department of
Energy &
Environment
Grant
Federal
The program receives funding from EPA's
Clean Water State Revolving Fund (CWSRF)
and can cover up to 55% of a project's total
cost. Project applicants must provide at least
45% of their project's costs using any non-
Federal funding source. This is referred to a
local match, which means that it can be
contributed from any non-Federal funding
source. The District of Columbia's Clean
Water Construction (CWC) Grant Program
may provide funding for design and
construction of projects that contribute
towards the District of Columbia's
compliance with the Clean Water Act (CWA).
Request to be added to the CWC
Stakeholder list so that notice of the funding
opportunity is emailed as soon as the
opportunity opens. Determine whether the
proposed project would be categorized as
Stormwater Green Infrastructure,
Stormwater Grey Infrastructure Project, or
Sewage Infrastructure. Obtain written
permission to perform work from property
owner. This could be DDOT, DPR, NPS, DCHA,
etc. Calculate the total project cost, federal
funding request (up to 55% of the total
project cost) and local match requirement
(at least 45% of the total project cost).
Secure a source of local match funding.
Write proposal to directly address scoring
criteria found in the Project Priority Rating
system (PPRS) and include all elements and
documents required by the Request for
Applications.
https://doee.
dc.gov/servic
e/clean-
water-
construction-
grant-
program-
resources-
funding-
applicants
Application
process, Fund
allocation to
states and
localities,
Grant
program
Capital,
Compliance,
Other
Applicants must provide
at least 45% of their
projects cost using any
non-Federal funding
source, "local matching."
Eligible projects: (1) Sewage
Infrastructure Projects, (2)
Stormwater Grey Infrastructure
Projects, and (3) Stormwater Green
Infrastructure Projects.
DC
14
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Districtwide
Cost-Share
Funding
St. Johns River
Water
Management
District
Grant
State
Offers several cost-sharing programs
throughout the year for projects that assist
in creating sustainable water resources,
provide flood protection and enhance
conservation efforts. Funding may be
available for local governments, agricultural
interests and other entities. In general,
projects considered for funding shall benefit
one or more of the four district core mission
areas, including: water supply, water quality,
natural systems restoration, and/or flood
protection. Funding is limited exclusively to
construction-related costs. The District will
fund up to 33% of the construction costs for
selected alternative water supply, water
quality, flood protection, and natural
systems projects and up to 50% for water
conservation projects.
Detailed guidance on completing an
application can be found online.
https://www.
sjrwmd.com/I
ocalgovernm
ents/funding/
#FY2018-
2019-general
Application
process
Capital
Cost sharing program for
construction project
related to alternative
water supply, water
quality, flood protection,
and natural systems
projects and up to 50 %
for water conservation
projects.
Projects are eligible for a
maximum district cost-share of
$1.5 million per project or per
applicant.
Construction costs. Must start by
June 30, 2019 or completed by Sept
30, 2020. Up to 33% of cost of
construction, 50% for construction of
water conservation projects, and
100% for REDI.
FL
Emergency
Streambank
and Shoreline
Protection
U.S. Army Corps
of Engineers
(USACE)
Public-
private
partner
ship
Federal
The U.S. Army Corps of Engineers (USACE) is
authorized to construct bank protection
works to protect endangered highways,
highway bridge approaches, and other
essential, important public works, such as
municipal water supply systems and sewage
disposal plants, churches, hospitals, schools,
and nonprofit public services and known
cultural sites that are endangered by flood-
caused bank or shoreline erosion. (The
website provided is an example from one
USACE district.)
Requests can be made by a sponsoring
agency empowered under State law to
provide local partnership. Identify your
USACE district and point of contact at
http://www.usace.army.mil/Locations/.
http://www.
mvr.usace.ar
my.mil/Busin
ess-With-
Us/Outreach-
Customer-
Service/Flood
-Risk-
Management
/Section-14/
Long-term
program,
Non-
competitive
process
Capital, Other
Formal assurance in the
form of a Project
Partnership Agreement
must be executed with
the project sponsor. All
PDA costs after the first
$100,000 are cost shared
50/50. All construction
costs are cost shared 65%
Federal and 35% non-
Federal.
The first $100,000 of the Planning
Design Analysis (PDA) phase
(normally limited to 12 months) is
a Federal expense. Each project is
limited to a total Federal cost of $5
million.
Project limit to total federal cost of
$5 million. Complete and deliver a
"request from a sponsoring agency
empowered under State law to
provide local partnership." Private
property and facilities not eligible for
protection.
National
Energy
Efficiency and
Solar Grants
Program
State of
Washington -
Department of
Commerce
Grant
State
Energy efficiency and solar grant funds
projects result in energy and operational
cost savings at state public higher education
institutions, local government facilities, state
agencies and K-12 public school districts.
This program is awarded through a
competitive process.
Eligible applicants include Washington State
public entities, such as municipalities and
districts. 20% of funds are reserved for
projects in small towns or cities with
populations of 5,000 or fewer. Applicants
who have not received funding previously
will be prioritized. No funding rounds are
currently open.
https://www.
commerce.w
a.gov/growin
g-the-
economy/ene
rgy/energy-
efficiency-
and-solar-
grants/
Application
process,
Competitive
process,
Grant
program
Capital, Other
Minimum matching
applies. Other State funds
cannot be used as match.
$500,000
Eligible projects include those that
will result in reduced energy
(electricity, gas, water, etc.) and
operational cost savings; installation
of grid-tied solar PVs (additional
points awarded for "Made in
Washington" components).
WA
Environmental
Education (EE)
Grants
Program
U.S.
Environmental
Protection
Agency (EPA)
Grant
Federal
Under the Environmental Education (EE)
Grants Program, EPA seeks grant proposals
from eligible applicants to support
environmental education projects that
promote environmental awareness and
stewardship and help provide people with
the skills to take responsible actions to
protect the environment. This grant program
provides financial support for projects that
design, demonstrate, and/or disseminate
environmental education practices,
methods, or techniques.
No proposals solicited for FY 2019. Check
https://www.epa.gov/education/environme
ntal-education-ee-grants for updates.
https://www.
epa.gov/educ
ation/environ
mental-
education-ee-
grants
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Grant
program
Other,
Outreach
Environmental education
Between $2 and $3.5 million total
in grant funding per year.
Must be an eligible organization,
located in the United States or
territories and the majority of the
educational activities must take place
in the US. Application must
completed in accordance with the
request for proposal (RFP).
National
15
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Environmental
Justice Small
Grants
Program
U.S.
Environmental
Protection
Agency (EPA)
Grant
Federal
Supports and empowers communities
working on solutions to local environmental
and public health issues. The program is
designed to help communities understand
and address exposure to multiple
environmental harms and risks.
EPA requires applications for Environmental
Justice (EJ) grants to be submitted
electronically through the Grants.gov
website. Hardcopy mailed or delivered
applications are only accepted if the
applicant has a waiver on file. For more
information, see Grants.gov.
https://www.
epa.gov/envir
onmentaljusti
ce/environme
ntal-justice-
small-grants-
program
Application
process,
Grant
program
Other,
Outreach
Applicants are added to EJ
Grants Applicant Database
to help EPA EJ program ID
and work with additional
underserved communities
outside of the context of
the grants.
Approximately 40 one-year
projects will be awarded at
$30,000 each.
Grants for a one year community-
driven projects designed to engage,
educate, and empower communities.
Grants for tribal organizations,
nonprofit organizations, federally-
recognized tribal governments.
National
Environmental
Workforce
Development
and Job
Training
(EWDJT)
Grants
U.S.
Environmental
Protection
Agency (EPA)
Grant
Federal
Funds are available for Environmental
Workforce Development and Job Training
(EWDJT) programs that recruit, train, and
place local, unemployed and under-
employed residents with the skills needed to
secure full-time employment in the
environmental field.
See application online
(https://www.epa.gov/grants/how-apply-
grants).
https://www.
epa.gov/grant
s/fy-2018-
environmenta
l-workforce-
development-
and-job-
training-
ewdjt-grants
Application
process,
Grant
program
Other,
Outreach
$200,000
Must be an eligible entity, cannot
have received the grant the previous
year. Eligible: local government, land
clearance authority, state
government, nonprofit organization,
Alaska Native Village, tribe,
redevelopment agency, regional
council, and more.
National
Feasibility and
Pre-
Development
Loans
Rural
Community
Assistance
Corporation
(RCAC)
Loan
Private
Loans provide the early funds small rural
communities need to determine project
feasibility and to pay pre-development costs
prior to receiving state and federal funding.
Projects must be located in rural areas with
populations of 50,000 or less in RCAC service
region.
Application forms are provided online.
Eligible applicants: Nonprofit organizations,
public agencies, tribes, and low-income rural
communities with a population of 50,000 or
less, or 10,000 or less if proposed permanent
financing is through U.S. Department of
Agriculture (USDA) Rural Development (RD).
https://www.
rcac.org/lendi
ng/environm
ental-loans/
Application
process, Loan
program
Other
$50,000 (feasibility loan), $35,000
(pre-development loan).
Eligible projects: Water, wastewater,
stormwater, and solid waste
planning; environmental work; and
other work to assist in developing an
application for infrastructure
improvements.
Rural
Western
US
Federal
Highway
Administration
(FHWA)
National
Highway
Performance
Program
(NHPP)
U.S.
Department of
Transportation
(DOT)
Grant
Federal
Provides support for the National Highway
System to construct new facilities and
ensure that investments of Federal-aid funds
in highway construction are directed to
support progress toward the performance
targets in a State's asset management plan.
States may transfer up to 50% of NHPP funds
the Surface Transportation Program,
Highway Safety Improvement Program, and
the Congestion Mitigation and Air Quality
(CMAQ) Program.
FHWA apportions funding as a lump sum for
each State then divides that total among
apportioned programs. Within this process, a
State's NHPP apportionment is calculated
based on a percentage specified in law. 2%
of a State's NHPP funding is to be set aside
for State Planning & Research.
https://www.
fhwa.dot.gov/
fastact/factsh
eets/nhppfs.c
fm
Fund
allocation to
states and
localities
Capital
Eligible activities include: installation
of vehicle-to-infrastructure
communication equipment,
reconstruction, resurfacing,
restoration, rehabilitation, or
preservation of a bridge on non-NHS
Federal-aid highway, project to
reduce risk of failure.
National
Federal
Highway
Administration
(FHWA)
Surface
Transportation
Block Grant -
Transportation
Alternatives
Set-Aside
U.S.
Department of
Transportation
(DOT)
Grant
Federal
Provides funding for transportation
alternatives, including off-road trail facilities
for pedestrians, bicyclists, and other non-
motorized forms of transportation. TAP
funding could be used to pay for green
infrastructure components of trails and
sidewalks such as permeable pavements.
https://www.
fhwa.dot.gov/
environment/
transportatio
n_alternative
s/
Application
process,
Competitive
process,
Grant
program,
One-time
allocation
Capital
Eligible projects include: on and off
road pedestrian and bicycle facilities,
infrastructure projects for improve
non-driver access to public
transportation, and historic
preservation and vegetation
management.
National
Federal
Highway
Administration
(FHWA)
Congestion
Mitigation and
Air Quality
(CMAQ)
program
U.S.
Department of
Transportation
(DOT)
Grant
Federal
Allocates federal funding for infrastructure
projects that reduce congestion and improve
air quality. Bicycle transportation and
pedestrian walkways are eligible uses of the
money, and can be designed to include
green infrastructure features, such as
permeable surfaces for trails, and bioswales
and bioretention for areas adjacent to trail
surfaces.
FHWA apportions funding as a lump sum for
each State then divide that total among
apportioned programs. Once each State's
combined total apportionment is calculated,
funding is set-aside for the State's CMAQ
Program.
https://www.
fhwa.dot.gov/
environment/
air_quality/c
maq/
Application
process,
Grant
program,
One-time
allocation
Capital
Includes non-federal
share requirements.
Funds may be used for a
transportation project or program
that is likely to contribute to the
attainment or maintenance of a
national ambient air quality standard,
with a high level of effectiveness in
reducing air pollution.
National
16
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Five Star and
Urban Waters
Restoration
Grant Program
National Fish
and Wildlife
Foundation
(NFWF)
Grant
Federal
Seeks to develop community capacity to
sustain local natural resources for future
generations by providing modest financial
assistance to diverse local partnerships
focused on improving water quality,
watersheds and the species and habitats
they support.
All application materials must be submitted
online through NFWF's Easy grants system,
https://easygrants.nfwf.org.
http://www.n
fwf.org/fivest
ar/Pages/ho
me.aspx
Application
process,
Grant
program,
Long-term
program
Other,
Outreach
Major funding for the
grants is provided by
NFWF partnerships with
EPA, US Forest Service, US
Fish and Wildlife Service,
South Company, FedEx,
and Shell Oil Company.
Leverage other funds or
donation services.
Range from $20,000 to $50,000;
average is $30,000
uiuan and Rural Communities.
Focuses on stewardship and
restoration of coastal, wetland and
riparian ecosystem across the
country. Must include: on-the-
ground restoration, environmental
outreach, community partnerships,
measurable results, sustainability.
National
Flood
Mitigation
Assistance
Program
(FMA)
U.S. Federal
Emergency
Management
Agency (FEMA)
Grant
Federal
Authorized by Section 1366 of the National
Flood Insurance Act of 1968, with the goal of
reducing or eliminating claims under the
National Flood Insurance Program (NFIP).
FMA provides funding to States, Territories,
Federally-recognized tribes and local
communities for projects and planning that
reduces or eliminates long-term risk of flood
damage to structures insured under the
NFIP. FMA funding is also available for
management costs.
The Notice of Funding Opportunity (NOFO) is
posted on www.Grants.gov. Sub-applicants
submit mitigation planning and project sub-
applications to their State during the open
application cycle. After reviewing project and
planning applications to determine if they
meet the program's requirements, the
States, territories, or Federally-recognized
tribal governments prioritize and forward
the applications to their FEMA Regional
Office. Contact your FEMA regional office:
https://www.fema.gov/fema-regional-office-
contact-information.
https://www.
fema.gov/floo
d-mitigation-
assistance-
grant-
program
Application
process,
Grant
program
Capital
Funding is appropriated to
Congress annually.
Federal funding is
available for up to 75% of
the eligible activity costs
the rest must be non-
federal funds.
$160,000,000 total available in
FY18. Of this, $70,000,000 was
prioritized for community flood
mitigation proposals leaving an
estimated $90,000,000 available
for other FMA priorities. FEMA will
select remaining eligible
applications once all priorities are
met based on benefits to the NFIP.
Funding for State, U.S. Territories,
Federally recognized tribes, and local
communities. For projects and
planning to reduce flood risk.
National
Florida Clean
Water State
Revolving Fund
Loan Program
(CWSRF)
Florida
Department of
Environmental
Protection (DEP)
Loan
State
Funds are made available for Planning Loans,
Design Loans and Construction Loans. Small,
disadvantaged communities may also be
eligible for grants, which, once qualified, can
significantly reduce the amount owed on the
loan.
Submit the appropriate Request for Inclusion
(RFI) Form. For a planning loan, the RFI is all
that is needed to be eligible to compete for
funding. For a design loan, the sponsor must
submit a RFI for design and the planning
process must be complete. For a
construction loan, all readiness to proceed
requirements must be compete and the RFI
for construction must be submitted 45 days
prior to the quarterly priority list meeting.
Application forms and guidelines can be
accessed on website.
http://www.d
ep.state.fl.us/
water/wff/cw
srf/
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
The program is funded by
federal grants, state
matching funds, loan
repayments and interest
earnings. Loan
repayments provide a
continuing source of
funds for additional
projects.
None
As of 2017, the CWSRF Program
has awarded approximately $1.1
billion in funding for over 120
wastewater and stormwater
improvement projects during the
past five years.
Municipalities or local government,
planning, design, and/or construction
of water pollution control facilities.
FL
Florida
Drinking Water
State
Revolving Fund
(DWSRF)
Program
Florida
Department of
Environmental
Protection (DEP)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents available at:
https://floridadep.gov/wra/srf/content/drink
ing-water-program-manual. Applicants must
first complete Request for Inclusion on
Drinking Water Priority List, to determine
project eligibility and priority scoring.
Projects placed on the fundable portion of
the priority list are eligible for funding and
can complete the full application process.
https://florid
adep.gov/wra
/srf/content/
dwsrf-
program
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
FL
Florida Water
Quality
Restoration
Grants
Florida
Department of
Environmental
Protection (DEP)
Grant
State
Annually, the state legislature provides
funding for the implementation of best
management practices, such as regional
stormwater treatment facilities, designed to
reduce pollutant loads to impaired waters
from urban stormwater discharges.
The grant applications may be submitted at
any time throughout the year and are
reviewed and ranked in March, July, and
November annually. Deadline for submittal
of applications is the first business day of
each review period. To apply for a grant,
submit a TMDL Water Quality Restoration
Grant Application Form. Forms are online.
https://florid
adep.gov/wra
/319-tmdl-
fund
Application
process,
Grant
program
Capital
The applicant must
provide a minimum of 50
percent of the total
project cost in matching
funds, of which at least 25
percent is provided by the
local government.
None
Exact funding availability varies.
Must be a local Florida government,
and projects must be non-point
source related such as evaluation of
BMPs, non-point source pollution
reduction in the watershed, etc.
FL
17
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Funding
Assistance for
the U.S. Virgin
Islands under
the Clean
Water Act Title
II Construction
Grants
Program
U.S.
Environmental
Protection
Agency (EPA)
Grant
Federal
Provides grant funds to improve the
infrastructure of wastewater systems
located in the U.S. Virgin Islands (USVI). It is a
set-aside of the Clean Water State Revolving
Fund (CWSRF) allotment. Eligible applicants
must be located within USVI and be a public
body created under jurisdiction law having
authority for treatment, transport, or
disposal of domestic wastewater within USVI
or be a designated and approved
management agency authorized in a Water
Quality Management plan.
Applications must be submitted through the
State water pollution control agency to the
appropriate EPA Regional Office. The
standard application forms as furnished by
the Federal agency must be used for this
program. Applicants, except in limited
circumstances approved by the Agency,
must submit all initial applications for
funding through http://www.grants.gov.
https://www.
cfda.gov/inde
x?s=program
&mode=form
&tab=stepl&i
d=dc61dc54f
9305bcb9ce7
117edae505e
6
Application
process, Fund
allocation to
states and
localities,
Grant
program,
Non-
competitive
process
Capital, Other
Eligible entity is required
to pay not less than 45%
of the total costs of the
project or activity, which
may include services,
materials, supplies, or
other in-kind
contributions. Exceptions
on webpage.
$4,113,000 total for FY2017
Eligible: States, Puerto Rico, USVI,
Guam, American Samoa,
Commonwealth of the Northern
Marina Islands (CNMI), and tribes
within the US. For small and
disadvantage communities. Eligible
projects listed on webpage.
USVI,
American
Samoa,
CNMI,
Puerto
Rico,
Tribes
Georgia Clean
Water State
Revolving Fund
Loan Program
(CWSRF)
Georgia
Environmental
Finance
Authority
(GEFA)
Loan
State
Eligible CWSRF projects include: 1) Water
quality, water conservation and wastewater
treatment projects, such as constructing new
wastewater treatment plants; 2) Repairing
and replacing sewer and stormwater control
projects; 3) Implementing water
conservation projects and programs.
Applications are received year-round. Prior
to starting an application, review the
Application Part 1 Instructions. Applications
can be accessed on website.
http://gefa.ge
orgia.gov/cle
an-water-
state-
revolving-
fund
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan repayments provide
a continuing source of
funds for additional
projects.
None
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
Local governments looking to
develop environmental
infrastructure, preserve natural
resources, and promote economic
development.
GA
Georgia
Drinking Water
State
Revolving Fund
(DWSRF)
Georgia
Environmental
Finance
Authority
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents available at:
https://gefa.georgia.gov/water-
resources/application-process. SWP
activities identified in the FY19 IUP include:
continue comprehensive data and
information management systems including
instream flow and source water quality data
and operate, maintain, and collect flow and
quality data from surface waters for
evaluating impact to and protecting public
water supply sources.
https://gefa.g
eorgia.gov/w
ater-and-
sewer-
financing/drin
king-water-
state-
revolving-
fund
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs. Eligible projects
identified at:
https://gefa.georgia.gov/
water-and-sewer-
financing/drinking-water-
state-revolving-fund.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
GA
Georgia Equity
Fund
Georgia
Department of
Community
Affairs (DCA)
Grant
State
Provides financial assistance including
grants, loans and any other forms of
assistance to finance activities that will assist
applicants in promoting the health, welfare,
safety, and economic security of the citizens
of the state through the development and
retention of employment opportunities in
areas of greater need as defined by the
Georgia Business Expansion and Support Act
of 1994, as amended.
Applications are received year round. Pre-
applications and applications can be
accessed on website. Check official eligibility
at:
https://dca.ga.gov/sites/default/files/onegeo
rgia_official_map_12_2014_0.pdf
https://dca.g
a.gov/commu
nity-
economic-
development
/funding/one
georgia-
authority/equ
ity-fund
Application
process,
Grant
program,
Loan
program,
Long-term
program
Capital, Other
Funds for public activities
require local investment
and must demonstrate
potential return on
investment impact.
None
Award limits are based on the
number of counties supporting a
particular project. One county -
maximum of $200,000 per project.
Two Counties - maximum of
$300,000 per project. Three or
more counties - maximum of
$500,000 per project
No other forms of funding can be
available. For general-purpose local
governments, local government
authorities, and joint or multi-county
development authorities in rural
counties with high poverty rates.
GA
Georgia Equity
Fund
Georgia
Department of
Community
Affairs (DCA)
Loan
State
The purpose of the Georgia Equity Fund is to
provide a program of financial assistance
that includes grants, loans and any other
forms of assistance to finance activities that
will assist applicants in promoting the health,
welfare, safety, and economic security of the
citizens of the state through the
development and retention of employment
opportunities in areas of greater need as
defined by the Georgia Business Expansion
and Support Act of 1994, as amended.
Applicants encouraged to use Georgia Equity
Fund monies only when no other funding is
available.
https://dca.g
a.gov/commu
nity-
economic-
development
/funding/one
georgia-
authority/equ
ity-fund
Application
process,
Grant
program,
Loan program
Capital, Other
Financial underwriting of
sub-recipient company is
required.
Award limits are based on the
number of counties supporting a
particular project: One County "
Maximum of $200,000 per project;
Two County" Maximum of
$300,000 per project; Three or
more County" Maximum of
$500,000 per project.
Eligible entities: local governments,
local governments, local government
authorities, and joint or multi-county
development authorities in rural
counties suffering from high poverty
rates. Sub-recipients may be for-
profit or nonprofit.
GA
18
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Georgia-Pacific
Foundation:
Environment
Grant
Georgia-Pacific
Foundation
Grant
Private
Funds and supports community-based
programs, volunteer service projects,
disaster relief and other initiatives to
improve the quality of life in communities
where Georgia-Pacific operates. The
Foundation invests resources in: education,
environment, community enrichment, and
entrepreneurship. Core contributions
include projects for workforce development
and environmental initiatives. Environment
focus areas include resource conservation,
clean air, clean water, recycling, and
environmental education.
Charitable contribution requests are
reviewed on a rolling cycle throughout the
calendar year. Due to limited funding at
year-end, submission by October 31 is
encouraged. Applications are submitted
online.
https://www.
gp.com/com
munity
Application
process,
Grant
program
Other,
Outreach
None
Varies
Applicants must be 501(c)3 nonprofit
organizations, public schools, or
other qualified state of local
governmental entities. Must be
located within 30 miles of a Georgia-
Pacific manufacturing community.
GA
Great Lakes
Grant
Programs
U.S.
Environmental
Protection
Agency (EPA)
Grant
Federal
Funded activities under the program will
advance protection and restoration of the
Great Lakes ecosystem in support of (i) the
Great Lakes Restoration Initiative (GLRI) as
described in the Great Lakes Restoration
Initiative Action Plan II
(http://www.greatlakesrestoration.us/action
plan/index.html), (ii) the Great Lakes portion
of Objective 2.02 (Protect and Restore
Watersheds and Aquatic Ecosystems) of
EPA's 2014-2018 Strategic Plan, and/or (iii)
the Great Lakes Regional Collaboration
Strategy to Protect and Restore the Great
Lakes (http://www.glrc.us/strategy.html).
Schedules are established in Requests for
Proposals or Applications and in individual
solicitations and are published on the
program's website
(https://www.epa.gov/great-lakes-
funding/great-lakes-rfas). To be added to the
mailing list for announcements of funding
opportunities, register at
https://www.epa.gov/great-lakes-
funding/great-lakes-news-email-list.
https://www.
epa.gov/great
-lakes-
funding
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Grant
program
Capital, Other
Combining GLRI resources
with agency base budgets,
work with nonfederal
partners to implement
protection and
restoration projects.
For FY17: GLRI total: $300 million;
Grants: $65 million estimated;
GLLA: $40 million estimated.
Must meet focus areas and
categories listed on webpage. Grants
for planning, research, monitoring,
outreach and implementation
projects in furtherance of the Great
Lakes Restoration Initiative (GLRI)
and the Great Lakes Water Quality
Agreement (GLWQA).
IL, Ml,
OH, NY,
Wl, MN,
IN, PA
Greater
Minnesota
Public
Infrastructure
Grant Program
Minnesota
Department of
Employment
and Economic
Development
(DEED)
Grant
State
Helps stimulate new economic development,
create new jobs, and retain existing jobs
through investments in public infrastructure.
Provides grants to cities of up to 50% of the
capital costs of the public infrastructure
necessary to expand or retain jobs in the
area, increase the tax base, or expand or
create new economic development.
Applications are accepted on an open basis.
Forms are available online. Contact local
representatives for more information
(https://mn.gov/deed/government/financial-
assistance/community-funding/small-
cities.jsp#5).
http://mn.go
v/deed/gover
nment/financ
ial-
assistance/bu
siness-
funding/infra
structure/
Application
process,
Grant
program
Capital, Other
City must provide a match
of at least 50% of the
project capital cost. Can
be cash or in-kind.
$2,000,000
Must be a county outside of the
seven-county metropolitan area or
statutory or home rule city outside of
the seven county metro area.
Projects: publicly owned
infrastructure that support economic
development.
MN
H20
Pennsylvania -
Water Supply,
Sanitary Sewer
and Storm
Water Projects
Pennsylvania
Department of
Community &
Economic
Development
(DCED)
Grant
State
Provides single-year or multi-year grants to
municipalities or municipal authorities to
assist with the construction of drinking
water, sanitary sewer and storm sewer
projects.
Submit the on-line Department of
Community and Economic Development
Single Application for Assistance located at
www.esa.dced.state.pa.us.
http://dced.p
a.gov/progra
ms/h2o-pa-
water-supply-
sanitary-
sewer-storm-
water-
projects/#.W
H6XqflzWUk
Application
process,
Competitive
process,
Grant
program,
Long-term
program
Capital
Matching funds of not less
than 50% required. Single
or multi-year grants
(cannot exceed 6 years).
$500,000
$20,000,000
Eligible: Municipalities and Municipal
Authorities.
PA
Hawaii Clean
Water State
Revolving Fund
(CWSRF)
State of Hawaii
Department of
Health (DOH),
Environmental
Management
Division (EMD)
Loan
State
Assists in financing the construction of water
pollution control projects necessary to
prevent contamination of our groundwater
and coastal water resources and to protect
and promote the health, safety and welfare
of the citizens of the State of Hawaii.
Provides low interest loans to county and
state agencies to construct point source and
non-point source water pollution control
projects.
Projects must apply to be on the annual
priority list. Applications can be found online.
http://health.
hawaii.gov/w
astewater/ho
me/cwsrf/
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
By partially funding
projects, states can
leverage the CWSRF
funding to assist a greater
number of eligible
projects. Loan
repayments provide a
continuing source of
funds for additional
projects.
No maximum funding level. Funds
are distributed based on the
priority, number of applicants, and
total funds available.
Loans for county and state agencies:
Eligible projects include: construction
of publicly owned treatment works,
non-point source, national estuary
program projects, decentralized
wastewater treatment system,
stormwater, water conservation,
efficiency.
HI
19
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Hazard
Mitigation
Grant Program
(HMGP)
U.S. Federal
Emergency
Management
Agency (FEMA)
Grant
Federal
Helps communities implement hazard
mitigation measures following a Presidential
major disaster declaration. Hazard mitigation
is any action taken to reduce or eliminate
long-term risk to people and property from
natural hazards. Mitigation planning is a key
process used to breaking the cycle of
disaster damage, reconstruction, and
repeated damage.
Sub-applicants apply for funding. Consult
State and FEMA website for application
information (https://www.fema.gov/hazard-
mitigation-grant-program-guide-state/local-
governments). Contact your Local Mitigation
Planner of State Hazard Mitigation Officer
(SHMO) (https://www.fema.gov/state-
hazard-mitigation-officers) to learn more
about the application process.
https://www.
fema.gov/haz
ard-
mitigation-
grant-
program
Application
process,
Grant
program,
Long-term
program
Capital, Other
FEMA provides up to 75%
of the funds with the
remaining 25% coming
from various sources.
Depends on the federally
recognized disaster and current
appropriations.
Eligible applicants include:
individuals, businesses, and private
nonprofits via local governments.
Individuals may not apply directly but
must be sponsored by either a local
government, state agency, tribe, or
private nonprofit.
National
Housing and
Urban
Development
(HUD) Title 1
Home
Improvement
Loan
US Department
of Housing and
Urban
Development
(HUD)
Loan
Federal
Loans on single family homes may be used
for alterations, repairs and for site
improvements. Loans on multifamily
structures may be used only for building
alteration and repairs. Title 1 can be used in
conjunction with a 203(k) Rehabilitation
Mortgage. For additional information on that
program, call (800) 767-7468 and request
item number 2571.
HUD's Homeownership Centers do not
process Title 1 loans. A property owner may
apply at any lender (bank, mortgage
company, savings and loan association,
credit union) that is approved to make Title 1
loans. See a list of participating financial
institutions at
https://www.hud.gov/program_offices/housi
ng/sfh/lender/lenderlist. The applicant must
be able to repay the loan in regular monthly
payments. Any loan over $7,500 must be
secured by a mortgage or deed of trust on
the property. New homes must have been
occupied for 90 days.
https://www.
hud.gov/prog
ram_offices/h
ousing/sfh/titl
e/ti_abou
Application
process, Loan
program
Capital, Other
Must be used in
conjunction with a 203(k)
Rehabilitation Mortgage.
Interest rate is fixed.
Single family house - $25,000
Manufactured house on
permanent foundation (classified
and taxed as real estate) - $25,090;
Manufactured house (classified as
personal property) - $7,500;
Multifamily structure - an average
of $12,000 per living unit, up to a
total of $60,000
Must be able to repay loan in a
regular monthly payment. Both large
and small improvements can be
financed. Not for property
improvements. Improvements must
protect or improve the basic livability
of or utility of the property. Occupied
for 90 days.
National
Hurricane and
Storm Damage
Reduction
Projects
U.S. Army Corps
of Engineers
(USACE)
Public-
private
partner
ship
Federal
Section 103 of the 1962 River and Harbor Act
authorizes the U.S. Army Corps of Engineers
(USACE) to study, design, and construct
small coastal storm damage reduction
projects in partnership with non-Federal
government agencies, such as cities,
counties, special authorities, or units of state
government.
Identify USACE district and point of contact
for requesting assistance at
http://www.usace.army.mil/Locations/.
https://www.
nae.usace.ar
my.mil/Missio
ns/Public-
Services/Cont
inuing-
Authorities-
Program/Sect
ion-103/
Long-term
program
Capital, Other
Costs for preparation of
plans and specifications
and construction are
shared at 65%
Federal/35% non-Federal.
The maximum Federal cost for
planning, design, and construction
of any one project is $10,000,000.
The Feasibility Study is 100%
federally funded up to $100,000.
Costs over $100,000 are shared
equally with the non-federal
sponsor.
Initial appraisal in Feasibility Study.
Solution must be economically
feasible and environmentally
acceptable. Projects in partnership
with non-Federal government
agencies, such as cities, counties,
special authorities, or units of state
government.
National
Idaho Public
Wastewater
System
Construction
Loans
Idaho
Department of
Environmental
Quality
Loan
State
Provides below-market-rate interest loans to
help build new or repair existing wastewater
treatment facilities. Eligible wastewater
facilities include treatment plants,
interceptor sewers, and collector sewers.
Loans of up to 100% of project costs may be
awarded for facility design and/or
construction projects. Loans also may be
awarded to address non-point source
pollution control activities. Eligible non-point
source activities include projects such as
effluent trading, upgrading or replacing
individual septic tanks, restoring wetlands,
treating and controlling stormwater, and
reducing pollutants from agricultural runoff.
Application process is outlined in the State of
Idaho's loan handbook
(http://www.deq.idaho.gov/media/1117872/
ww-loan-handbook.pdf) and begins with a
pre-application conference. Application
includes six components.
https://www.
deq.idaho.go
v/water-
quality/grants
loans/wastew
ater-system-
construction-
loans/
Application
process, Loan
program,
Long-term
program
Capital, Other
Loan repayments and
interest earnings provide
resources for new water
pollution loans.
Eligible entities: Counties, cities,
special service districts,
governmental entities, and nonprofit
corporations with authority to
collect, treat, or dispose of sewage or
industrial wastewater.
ID
20
-------
Program Name
Idaho Public
Water System
Construction
Loans
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Idaho
Department of
Environmental
Quality (DEQ)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. In FFY 2019 the DEQ reserved
$1,100,400 of the capitalization grant for
SWP. Funds were identified for use to assess
public drinking water sources to characterize
the water source and determine its
susceptibility to contamination and assist
with developing and implementing SWP
plans; implement SWP projects and develop
tools and resources to facilitate SWP
implementation efforts; and provide SWP
education, outreach, training, and technical
assistance to owners and operators of public
water systems, staff at local governments,
schools, businesses, and the public.
Funding applications and forms are available
at:
http://www.deq.idaho.gov/media/1117871/
dw-loan-handbook.pdf and
http://www.deq.idaho.gov/media/1118137/
2-a-dw.pdf Interested parties must submit a
Letter of Interest (LOI) to the DEQ indicating
a desire for funding. The LOI is evaluated
using a rating and ranking system and are
found eligible for placement on the State's
priority list are placed on the Intended Use
Plan (IUP).
https://www.
deq.idaho.go
v/water-
quality/grants
-loans/water-
system-
construction-
loans/
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
ID
Illinois Public
Water Supply
Loan Program
(PWSLP)
Illinois
Environmental
Protection
Agency
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Applicants must submit a Funding
Nomination Form to be included on the
Intended Funding List. Application
documents available at:
https://www2.illinois.gov/epa/topics/grants-
loans/state-revolving-fund/Pages/state-
revolving-fund-forms.aspx.
https://www
2.illinois.gov/
epa/topics/gr
ants-
loans/state-
revolving-
fund/Pages/d
efault.aspx
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
IL
Illinois Water
Pollution
Control Loan
Fund Program
(WPLCP)
Illinois
Environmental
Protection
Agency (EPA)
Loan
State
Funds wastewater and stormwater projects.
The yearly cycle is based on the state of
Illinois fiscal year, which starts July 1st and
ends June 30th. Because funding is limited,
projects with approved planning are scored
and ranked to prioritize which ones will
receive loan program resources during a
specific fiscal year. See online instructions
and forms for guidance.
https://www
2.illinois.gov/
epa/topics/gr
ants-
loans/state-
revolving-
fund/Pages/d
efault.aspx
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan repayments provide
a continuing source of
funds for additional
projects.
None
Must have an enforceable water or
sewer ordinance, a user charge
ordinance, a certified local debt
authorization ordinance, and a
dedicated revenue stream to assure
repayment.
IL
Indiana Clean
Water Act
Section 205(J)
Grants
Indiana
Department of
Environmental
Management
(IDEM)
Grant
State
The Clean Water Act (CWA) Section 205(j)
program provides for projects that gather
and map information on non-point and point
source water pollution, develop
recommendations for increasing the
involvement of environmental and civic
organizations in watershed planning and
implementation activities, and develop and
implement watershed management plans.
Indiana's priorities for funds are developing
watershed management plans and restoring
ecosystems critical to water quality.
Applications must be typed and submitted
using the approved application form. The
application form (53970) can be found on
the IDEM Forms page
(http://www.in.gOv/idem/5157.htm#owq_w
atershed). Applications must be submitted
electronically (email or disk) and in signed,
hard-copy format.
https://www.i
n.gov/idem/n
ps/2525.htm
Application
process,
Competitive
process, Loan
program
Capital, O&M
Federal pass-through
grant program for water
quality management
planning.
None
Averages $350,000 total annually.
Up to $80,000 per project
typically.
Must be sponsored by municipal
government, county government
regional planning commission, or
other government agency, must work
on water quality management
planning & design. Used to
determine the nature, extent and
causes of point & non-point
pollution.
IN
21
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Indiana
Drinking Water
State
Revolving Fund
(DWSRF)
Indiana Finance
Authority
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Applicants must submit a loan application
and then participate in a Project Planning
Meeting and subsequently submit a
Preliminary Engineering Report (PER) to be
ranked and scored on the Project Priority List
(PPL). Application information and
documents available at:
https://www.in.gov/ifa/srf/2387.htm.
https://www.i
n.gov/ifa/srf/
2387.htm
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
IN
Indiana
Wastewater
State
Revolving Fund
(WWSRF) Loan
Program
Indiana Finance
Authority (IFA)
Loan
State
Provides low-interest-rate financing to
construct water quality protection projects.
Stormwater projects that have no water
quality benefits are not eligible for WWSRF
financing. The Program has provided more
than $1.84 billion in financing to Indiana
communities since the program's first loan
closing in 1991.
Applicants' projects must be ranked on
annual priority list in the state Intended Use
Plan (IUP). Applications can be found online.
Contact your state office for more
information.
https://www.i
n.gov/ifa/srf/
2386.htm
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
WWSRF Loan receives
capitalization grants and
uses these grants and
repayments and
leveraging in open market
to allow more money to
be available at a low
interest rate for eligible
projects.
None
Must be a political subdivision (cities,
town, or county), regional
sewer/water district, and
conservancy district, with a water
quality project that could include:
Treatment plant upgrade and
improvement, sewer line extension,
combined sewer correction.
IN
Infrastructure
Financing
Border
Environment
Cooperation
Commission
(BECC)
Loan
Federal
BECC's Technical Assistance fund supports
the development of water and wastewater
projects ineligible to receive Project
Development Assistance Program (PDAP)
funding, as well as all other BECC-North
American Development Bank (NADB) eligible
project types. Finances projects that
prevent, control or reduce environmental
pollutants, improve drinking water supply, or
protect flora and fauna.
Online application:
http://www.becc.org/certification-
process/apply-for-certification-financing.
http://www.b
ecc.org/fundi
ng-
programs/tec
hnical-
assistance/ta-
fund
Application
process, Loan
program
Capital
None
Varies (funds are derived from
BECC's operating budget). See
http://www.becc.org/applications/
technical-assistance-approved for
examples of approved TA
agreements.
Project must be located within 100
km (62 miles) north of the
international boarder between
Mexico and US or 300 KM south.
Cannot finance more than 85% of
project cost. Funding from other
sources is required.
TX, NM,
AZ, CA
Insular Areas
Community
Development
Block Grant
(CDBG)
Program -
Insular Areas
U.S.
Department of
Housing and
Urban
Development
(HUD) Field
Offices in
Puerto Rico and
Hawaii
Grant
Federal
CDBG funds may be utilized to address a
wide variety of community needs, including
construction or renovation of various
infrastructure projects such as water,
wastewater and solid waste facilities, streets,
and flood control projects. The funds must
be used for activities that either benefit low-
and moderate-income persons or address
community development needs that have a
particular urgency.
In order to receive CDBG funds, insular areas
must submit a Consolidated Plan or an
abbreviated Consolidated Plan to their HUD
field office. U.S. Virgin Islands: San Juan
(Caribbean) Field Office; All others: Honolulu
Field Office. Contact Information:
https://www.hudexchange.info/programs/cp
d-field-office-
directory/https://www.hudexchange.info/pr
ograms/cpd-field-office-directory/
https://www.
hudexchange.
info/program
s/cdbg-
insular-areas/
Fund
allocation to
states and
localities,
Grant
program,
Long-term
program
Capital, O&M,
Other
Under Section 106 of the Housing
and Community Development Act
of 1974, $7 million of the Title 1
CDBG appropriation is allocated
for grants to insular areas. Funds
for Section 107 grants are
allocated to the insular areas and
other programs as directed by the
present year's appropriations act.
Grants fund four designated areas:
American Samoa; Guam; Northern
Mariana Islands; and the U.S. Virgin
Islands. Not less than 70% of CDBG
funds must be used for activities that
benefit low- and moderate-income
persons.
American
Samoa,
Guam,
Northern
Mariana
Islands,
U.S. Virgin
Islands
Intermediate
Term Loan
Rural
Community
Assistance
Corporation
(RCAC)
Loan
Private
RCAC's loan fund is a financial source for
rural communities in the west.
Applications are located online. Eligible
applicants: Nonprofit organizations, public
agencies, tribes, and low-income rural
communities with a population of 50,000 or
10,000 or less if proposed permanent
financing is through U.S. Department of
Agriculture (USDA) Rural Development (RD).
http://www.r
cac.org/lendi
ng/environm
ental-loans/
Application
process, Loan
program
Capital
$100,000 for smaller capital needs
(up to 20-year term).
Eligible projects: Water, wastewater,
solid waste and stormwater facilities
that primarily serve low-income rural
communities.
Rural
Western
US
22
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Investments
for Public
Works and
Economic
Adjustment
Assistance
Programs
U.S.
Department of
Commerce -
Economic
Development
Administration
(EDA)
Loan
Federal
Empowers distressed communities to
revitalize, expand, and upgrade their physical
infrastructure, and generate or retain long-
term, private sector jobs and investment.
EDA invests in traditional public works
projects, including water and sewer systems
improvements, industrial parks, business
incubator facilities, expansion of port and
harbor facilities, skill-training facilities, and
brownfields redevelopment.
Applications will be accepted on an ongoing
basis until the publication of a new Economic
Development Assistance programs (EDAP)
Federal Funding Opportunity (FFO). More
information can be found in the Notice of
funding opportunity here:
https://www.eda.gov/funding-
opportunities/.More information here:
https://www.grants.gov/web/grants/search-
grants.html?keywords=EDA%E2%80%99s%2
0Public%20Works%20and%20Economic%20
Adjustment%20Assistance%20programs
https://www.
eda.gov/prog
rams/eda-
programs/
Application
process, Loan
program
Capital, Other
$100,000
$3,000,000
For state and local entities.
National
Iowa Clean
Water State
Revolving Fund
(CWSRF)
Iowa
Department of
Natural
Resources
(DNR)
Loan
State
Provides financing for publicly owned
wastewater treatment, sewer rehabilitation,
replacement, and construction, and
stormwater quality improvements.
Projects must apply to be on the annual
priority list. Applications can be found online.
Contact state office for more information.
http://www.i
owasrf.com/p
rogram/clean
_water_loan_
program/
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan interest payments
provide a continuing
source of funds for
additional projects.
None
Initial meeting prior to planning
process, public construction project.
Funding for: publicly owned
wastewater treatment, sewer
rehabilitation, replacement, and
construction, and stormwater quality
improvements.
IA
Iowa Drinking
Water State
Revolving Fund
(DWSRF)
Program
Iowa
Department of
Natural
Resources
(DNR) and the
Iowa Finance
Authority (IFA)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. SWP activities authorized include
coordination and administration of the SWP
program, contracts for services to develop
SWP plans and review implementation of
Best Management Practices, development of
data for Phase 1 SWP assessments for all
new systems and new wells at existing public
water supply systems, technical assistance
for well sitting, and maintenance of the
Source Water Mapper and Tracker online
database.
Application documents available at:
https://www.iowadnr.gov/Environmental-
Protection/Water-Quality/Water-Supply-
Engineering/State-Revolving-Loan-Fund.
Applicants must first submit an Intended Use
Plan (IUP) application to request inclusion on
the IA DWSRF IUP before submitting an
application for a SRF loan.
http://www.i
owasrf.com/p
rogram/drinki
ng_water_loa
n_program/
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
IA
Iowa
Watershed
Improvement
Fund
Iowa
Department of
Agriculture and
Land
Stewardship
(DALS)
Grant
State
The Watershed Improvement Review Board
(WIRB) was established to provide grants to
improve water quality and flood prevention.
See FAQs for more information:
https://www.iowaagriculture.gov/IWIRB/iwir
bQandA.asp.
A Request for Applications (RFA) will be
announced periodically. The frequency of
RFA announcements will vary with the
availability of funds and the number of
applications received and funded previously
from the same appropriation. A news release
will be submitted to statewide media
outlets.
http://www.i
owaagricultur
e.gov/IWIRB/i
wirbWhoAre
We.asp
Application
process,
Grant
program,
Long-term
program
Capital, Other
10% of the annual appropriation to
the fund from the legislature.
For watershed and water quality
projects.
IA
23
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Kansas Public
Water Supply
Loan Fund
(KPWSLF)
Kansas
Department of
Health and
Environment
(KDHE)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents available at:
http://www.kdheks.gov/pws/loansgrants/ap
plications.html. In order for the municipality
to be eligible for a Kansas Public Water
Supply Loan Fund loan it must first be listed
on the Project Priority List. A project
submittal form must be submitted to KDHE
to receive consideration for the Project
Priority List. All Public Water Supply Section
funding programs require the municipality to
adopt and implement a Water Conservation
Plan consistent with guidelines developed by
the Kansas Water Office.
http://www.k
dheks.gov/pw
s/loansgrants
/loansgrants.
html
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more. Projects that are needed solely
for future growth or fire protection
cannot be considered for funding.
KS
Kansas Small
Systems
Planning
Grants
Kansas
Department of
Health and
Environment
(KDHE)
Grant
State
Provides funding towards the development
of a preliminary engineering report for public
systems serving a population below 3,300
and with a score of 11 or more on EPA's
Enforcement Response Policy List.
Application and guidelines can be found
online.
http://www.k
dheks.gov/pw
s/loansgrants
/applications,
html
Application
process,
Grant
program
Capital,
Compliance
Dollar for dollar matching
for preliminary
engineering studies to
identify solutions to
resolve compliance issues
for small public systems.
50% cost-share match up to a
maximum of $5,000.00 to the
small water system for
development of a preliminary
engineering study.
Population served must be 3,300 or
less, have a score of 11 or more on
EPA's Enforcement Response Policy
List, a current or sporadic MCL
violation or infrastructure
improvement related to deficiency,
willing to correct deficiencies.
KS
Kansas Water
Pollution
Control
Revolving Loan
Fund
(KWPCRF)
Kansas
Department of
Health and
Environment
(KDHE)
Loan
State
Finances water pollution control
construction projects through low interest
loans to local governments and also provides
technical assistance.
A project submittal form must be submitted
to KDHE prior to submitting a final loan
application. Project submittal forms and
applications can be accessed at
www.kdheks.gov/muni/index.htm .
http://www.k
dheks.gov/m
uni/index.ht
m
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
In some years, the
KWPCRF has leveraged
the program by issuing
additional revenue bonds.
Loan repayments provide
a continuing source of
funds for additional
projects.
Total current funding level is
estimated at $100,000,000 but will
vary based on cash flow demand.
Project must be on the Project
Priority List. If project exceeds
$10,000,000, a value engineering
study must be completed.
KS
Kentucky
Clean Water
State
Revolving Fund
(CWSRF)
Kentucky
Infrastructure
Authority (KIA)
Loan
State
The CWSRF, also referred to as Fund A, is a
20-year loan program for planning, design
and construction of wastewater
infrastructure projects, stormwater projects
and non-point source projects. Fund A1
provides assistance to small communities in
financing the preliminary costs prior to
construction. It is a five-year loan for
planning, design and sanitary sewer
evaluation study (SSES). If a community
applies for a loan for the construction
portion of the project under Fund A, the
Fund A1 can be rolled over to the Fund A
loan.
Contact the Kentucky Infrastructure
Authority (KIA). To be considered for SRF
funding, the project must be included on the
Project Priority List. The open Call for
Projects is conducted annually in October of
each year.
http://water.
ky.gov/Fundi
ng/Pages/Cle
anWaterState
RevolvingFun
d.aspx
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan repayments provide
a continuing source of
funds for additional
projects.
$50,000,000
Loan for planning, design, and
construction of wastewater
infrastructure, stormwater, and non-
point source projects.
KY
Kentucky
Drinking Water
State
Revolving Fund
(DWSRF)
Kentucky
Department for
Environmental
Protection
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
A public water system (PWS) submits a
project profile to its local Area Development
District who then sends a prioritized list of
projects to the state. Application documents
available at:
https://eec.ky.gov/Environmental-
Protection/Water/Funding/srfforms/Pages/d
efault.aspx.
https://eec.ky
.gov/Environ
mental-
Protection/W
ater/Funding/
DWSRF/Pages
/default.aspx
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
KY
24
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Land
Acquisition
Loans
Maine
Department of
Health and
Human Services
Center for
Disease Control
and Prevention
Drinking Water
Program
Loan
State
Provides low interest loans to community
and nonprofit, non-community public water
systems for the purchase or legal control of
land in drinking water source protection
areas. Land acquisition is a key component
of safe and secure drinking water and the
protection of public health. Shoreline and
direct watershed land use and development
have major impacts on the quality of water
available to a water system and control of
those lands is an extremely cost-effective
way of managing future water treatment
costs.
Applications available on the Maine CDC
Drinking Water Program website,
www.medwp.com.
http://www.
maine.gov/dh
hs/mecdc/en
vironmental-
health/dwp/p
ws/financiaIR
esources.sht
ml
Application
process, Loan
program,
Long-term
program
Capital, Other
None
No project limit; based on available
funds at time of loan application.
Community, nonprofit, non-
community public water system.
Federal agencies not eligible.
Purchase of land and/or conservation
easements for source water
protection.
ME
Long Island
Sound Futures
Fund
National Fish
and Wildlife
Foundation
(NFWF), U.S.
Environmental
Protection
Agency (EPA),
Long Island
Sound Study
(LISS), and U.S.
Fish and Wildlife
Service (USFWS)
Grant
Federal
Supports projects that restore and protect
the health and living resources of Long Island
Sound. The Clean Water and Healthy
Watersheds program theme focuses on
improving water quality by delivering
projects that reduce Combined Sewer
Overflows, stormwater runoff, and non-point
source loading into Long Island Sound.
All application materials must be submitted
online through NFWF's Easy grants system
(www.nfwf.org/easygrants).
http://www.n
fwf.org/lisff
Application
process,
Grant
program
Capital, O&M
Matching at least 40% of
project budget.
$3,000
(education
grants)
$2 million is available. Funding
amount varies based on project
type but ranges from $3,000 to
$100,000.
Must be a 501(c), state government,
local government, municipal
government, Indian tribe, or
educational institution. Local projects
that aim to protect and restore Long
Island Sound (LIS). Must have a
Quality Assurance Project Plan
(QAPP) before start.
NY
Louisiana
Clean Water
State
Revolving Fund
(CWSRF)
Louisiana
Department of
Environmental
Quality (DEQ)
Loan
State
Offers low-interest loans to communities for
construction or upgrade of wastewater
treatment works and other water quality
improvement projects. Eligible projects
include: Construction of publicly owned
treatment works; implementation of a non-
point source pollution management
program; and implementation of an estuary
improvement program.
To apply, a pre-application and Louisiana
Water/Wastewater Joint Funding Committee
Intent to File Application must be completed
prior to submitting a CWSRF application.
Forms and additional information can be
accessed from links on website.
https://deq.lo
uisiana.gov/p
age/clean-
water-state-
revolving-
fund
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital, O&M,
Other
Interest and loan
repayments provide a
permanent source for
funding in future
Louisiana projects.
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
Project must be a construction of
publicly owned treatment works,
implementation of non-point source
pollution management program and
implementation of an estuary
improvement program.
LA
Louisiana
Drinking Water
Revolving Loan
Fund (DWRLF)
Louisiana
Department of
Health (LDH)
Office of Public
Health (OPH)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. LA also uses its 2% Small System
Technical Assistance set-aside to review
source water problems and identify/evaluate
technical options.
Specific documents must be completed and
submitted to the DWRLF Program any time a
water system intends to seek DWRLF
assistance. The application package is
available at:
http://ldh.la.gov/index.cfm/page/1333.
http://ldh.la.g
ov/index.cfm/
page/43l/n/2
85
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more. LA also uses 2% set-aside to
fund SWP technical assistance and
other related activities.
LA
25
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Maine Clean
Water State
Revolving Loan
Fund (CWSRF)
Maine
Department of
Environmental
Protection (DEP)
and Maine
Municipal Bond
Bank (MMBB)
Loan
State
The primary purpose of the fund is to
acquire, plan, design, construct, enlarge,
repair and/or improve publicly-owned
sewage collection systems, interceptor
sewers, pumping stations, and wastewater
treatment plants. In addition, the program
also funds public and private non-point
source water quality protection and
improvement projects.
To apply for a loan without an additional
subsidy, complete the CWSRF Notification of
Intent to Borrow form, submit it to the
Department as instructed, complete the SRF
Financial Application located on the MMBB
website, and submit it to the MMBB.
Applications are accepted on a rolling basis.
Forms can be found online.
http://www.
maine.gov/de
p/water/gran
ts/srfparag.ht
ml
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loans repayments fund
additional water quality
projects or improvement
projects.
None
Varies. Program can offer up to a
maximum of $4,969,200 in
additional subsidy.
Must be a municipality or quasi-
municipal corporation. Must be for
planning, design, and/or construction
of municipal wastewater treatment
works and other water pollution
control facilities or practices
including non-point source pollution
control.
ME
Maine Drinking
Water State
Revolving Fund
(DWSRF)
Maine Division
of
Environmental
and Community
Health
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Funding applications are available at:
https://www.maine.gov/dhhs/mecdc/enviro
nmental-health/dwp/pws/srf.shtml#Forms
Applicants must hold a meeting with DWSRF
Staff and other project members prior to the
start of project.
https://www.
maine.gov/dh
hs/mecdc/en
vironmental-
health/dwp/p
ws/srf.shtml
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Source Water Protection Grant
max is $10,000.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more. SWP efforts are not eligible for
funding with project funds.
ME
Marine Debris
Program
National
Oceanic and
Atmospheric
Administration
(NOAA)
Grant
Federal
Offers several nationwide, competitive
funding opportunities for marine debris
projects. Provides funding to support locally-
driven, marine debris prevention,
assessment, and removal projects that will
benefit coastal habitat, waterways, and
NOAA trust resources.
Visit
https://marinedebris.noaa.gov/funding/fund
ing-opportunities to view open funding
opportunities.
https://marin
edebris.noaa.
gov/
Application
process,
Grant
program,
One-time
allocation
O&M, Other
$50,000
For FY17, funding of up to
$2,000,000 was available for
Community-based Marine Debris
Removal Project Grants, with
individual awards expected to
range from $50,000 to $150,000.
In 2016, there were 12 recipients
of Marine Debris Prevention,
Education and Outreach
Partnership Grants totaling
$684,264.
Pre-proposal NOI. Must take place
within the United States or
territories, federal agencies are not
eligible.
National
Maryland
Drinking Water
Revolving Loan
Fund (DWRLF)
Maryland
Department of
the
Environment
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application process information and
documents not available on website.
https://mde.
maryland.gov
/programs/W
ater/WQFA/P
ages/drinking
_water_fund.
aspx
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
MD
Maryland
Water Quality
Revolving Loan
Fund (WQRLF)
Maryland
Department of
the
Environment
(DOE)
Loan
State
Provides financial assistance for a wide
variety of projects to protect or improve the
quality of Maryland's rivers, streams, lakes,
the Chesapeake Bay and other water
resources.
Projects must apply to be on the annual
priority list. Applications are accepted by
MWQFA from December 1 through January
31.
https://mde.
maryland.gov
/programs/W
ater/WQFA/P
ages/water_q
uality_fund.as
px
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan repayments provide
a continuing source of
funds for additional
projects.
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
Public entities: Point source pollution
prevention; Pubic and Private
entities: Non-point source pollution
prevention.
MD
26
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Massachusetts
Clean Water
State
Revolving Loan
Fund (CWSRF)
Massachusetts
Department of
Environmental
Protection (DEP)
Loan
State
Provides a low-cost funding mechanism to
assist municipalities in complying with
federal and state water quality
requirements. The program emphasizes:
Watershed management priorities,
Stormwater management, and Green
infrastructure.
The applicant must be able to file a complete
loan application no later than October 15.
Applications and guidelines can be accessed
on the website.
http://www.
mass.gov/eea
/agencies/ma
ssdep/water/
grants/clean-
water-state-
revolving-
fund.html
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan interest payments
provide a continuing
source of funds for
additional projects.
The current subsidy is provided via
a 2% interest loan. In recent years
the program has operated with
$400 to $450 million per year,
representing the financing of 50 to
70 projects annually.
Planning and construction projects
for CSO, New Wastewater treatment
facilities, wastewater collection
systems, Infiltration/Inflow (l/l)
correction, non-point source
abatement projects, green
infrastructure, certain waste nutrient
management projects.
MA
Massachusetts
State
Revolving Fund
(SRF) Loan
Program
Massachusetts
Department of
Environmental
Program (DEP)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Funding applications and forms are available
at: https://www.mass.gov/lists/State-
revolving-fund-applications-forms. To be
considered for the program the public water
supplier must complete a Project Evaluation
Form (PEF) and submit it by May.
Information required includes: showing
significant benefit to public health or
drinking water quality, local funding, and a
commitment that the loan application can be
filed in a timely manner. The project is then
ranked based on set criteria and funded
accordingly.
https://www.
mass.gov/ser
vice-
details/srf-
drinking-
water-
program
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
MA
Michigan
Clean Water
State
Revolving Fund
(CWSRF)
Michigan
Department of
Environmental
Quality (DEQ)
Loan
State
Low interest loan financing program that
assists qualified local municipalities with the
construction of needed water pollution
control facilities. The Green Project Reserve
is for projects with components that address
green infrastructure, water or energy
efficiency improvements, or other
environmentally innovative activities.
Applications and guidance forms can be
accessed on website. Applications must be
submitted by July 1.
https://www.
michigan.gov
/deq/0,1607,
7-135-
3307_3515_4
143—
,00.html
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan interest used to fund
future projects.
As of October 1, 2017, the SRF
program has provided low interest
loans for 582 projects, totaling
$4.8 billion.
In FY 2020 projects must address
green infrastructure, water or energy
efficiency improvements, or other
environmentally innovative activities.
Design and construction activities.
Ml
Michigan
Drinking Water
State
Revolving Fund
(DWSRF)
Michigan
Department of
Environment,
Great Lakes,
and Energy
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Funding applications and forms are available
at:
https://www.michigan.gOv/egle/0,9429,7-
135-3307_3515_3517-10784—,00.html The
application must be completed and
submitted to EGLE-WIFS@michigan.gov and
a Water Infrastructure Financing Section
(WIFS) project manager will follow-up.
Projects will be ranked and placed on the
Project Priority List (PPL). May 1 each year is
the annual cutoff date for submissions for a
new project. In 2019 the State set-aside
approximately $400,000 from the set-aside
to provide 50/50 match grants for local
communities to increase source water
protection.
https://www.
michigan.gov
/egle/0,9429,
7-135-
3307_3515_3
517—
,00.html
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
Ml
27
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Michigan
Nonpoint
Source
Pollution
Control Grants
- Clean
Michigan
Initiative
Michigan
Department of
Environmental
Quality
Grant
State
Provides funding to implement the physical
improvements in approved watershed
management plans intended to restore
impaired waters and protect high quality
waters. Practices must address specific
sources of non-point source pollution
identified by Michigan's Non-point Source
Program Plan. Physical improvements are
structural and vegetative best management
practices.
A request for proposals is announced with a
deadline for application. Eligible applicants
can contact DEQ Non-point Source staff for
grant application assistance. Prior to
application, locally developed watershed
management plans should be submitted to
the DEQ for review and approval.
http://www.
michigan.gov
/deq/0,4561,
7-135-
3307_3515-
314499-
,00.html
Application
process,
Grant
program
Capital
Grants required a 25%
match. Funding for
physical improvements in
approved watershed
management plan.
$25,000
Approximately $l-$2 million has
been available most funding
rounds. There is no maximum for
proposals submitted.
Ml
Michigan
Stormwater,
Asset
Management
and
Wastewater
(SAW)
Program
Michigan
Department of
Environmental
Quality (DEQ)
Grant
State
Provides grants for the development of plans
to identify and manage stormwater or
wastewater assets, stormwater treatment
management plans, planning and design of
sewage, stormwater, or non-point source
pollution reduction projects, and the testing
and demonstration of innovative water
quality improvement projects. Additionally,
low interest loans are available for
construction activities that protect water
quality and are identified in an asset
management program or and approved
stormwater management plan.
Applications information can found online.
Information was last updated in 2018,
stating no new applications have been
accepted since March 21, 2014.
http://www.
michigan.gov
/deq/0,4561,
7-135-
3307_3515_4
143-294952-
,00.html
Application
process,
Grant
program,
Non-
competitive
process
Capital
Matching may be
required.
None
Up to $2 million per municipality
with match of 10% for the first
million and 25% for the second
million.
Any municipality as defined by MCL
324.5301(i) is eligible to apply.
Planning, design, and construction.
Construction must start within three
years of award.
Ml
Michigan
Stormwater,
Asset
Management
and
Wastewater
(SAW)
Program
Michigan
Department of
Environmental
Quality
Loan
State
The Stormwater, Asset Management and
Wastewater program provides grants for the
development of plans to identify and
manage stormwater or wastewater assets,
stormwater treatment management plans,
planning and design of sewage, stormwater,
or non-point source pollution reduction
projects, and the testing and demonstration
of innovative water quality improvement
projects. Additionally, low interest loans are
available for construction activities that
protect water quality and are identified in an
asset management program or and
approved stormwater management plan.
Applications information can be found
online.
http://www.
michigan.gov
/deq/0,4561,
7-135-
3307_3515_4
143-294952-
,00.html
Application
process,
Grant
program,
Loan
program,
Long-term
program
Capital, Other
For grants, match of 10%
for the first million and
25% for the second
million.
For fiscal year 2018, $62 million
was appropriated for SAW award.
Grants are available up to $2
million per municipality.
Eligible applicants are municipalities
as defined in MCL 324.5301(i).
Eligible projects are construction
activities that address water quality
issues.
Ml
Minnesota
Clean Water
State
Revolving Fund
(CWSRF)
Minnesota
Public Facilities
Authority (PFA),
Minnesota
Pollution
Control Agency
Loan
State
Helps communities build or upgrade
wastewater treatment plants to comply with
discharge standards in the federal Clean
Water Act.
Projects must apply to be on the annual
priority list. Applications are accepted within
six months after the intended use plan is
approved using the PFA's loan application
forms. The IUP is compiled once a year but
may be amended.
https://mn.go
v/deed/pfa/fu
nds-
programs/cle
anwaterrevol
vingfund.jsp
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loans can be used for
bond issuance, and
certain fees and
contingency costs.
No maximum funding level.
Amount of funds given is
determined by project priority
level and total available funds that
fiscal year.
Cities, counties, townships, sanitary
districts or other governmental
subdivisions responsible for
wastewater treatment are eligible.
Land costs not allowable.
MN
28
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Minnesota
Drinking Water
Revolving Fund
(DWRF)
Minnesota
Public Facilities
Authority (PFA)
and the
Minnesota
Department of
Health (MDH)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents are available at:
https://mn.gov/deed/pfa/funds-
programs/drinking-water.jsp. Projects must
be included on the MDH's Project Priority
List and the Public Facilities Authority's
Intended Use Plan. In addition, projects must
be certified by the MDH before the PFA may
approve a loan.
https://mn.go
v/deed/pfa/fu
nds-
programs/dri
nking-
water.jsp
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
MN
Mississippi
Capital
Improvements
Revolving Loan
(CAP)
Mississippi
Development
Authority (MDA)
Loan
State
Provides loans to municipalities and counties
for the improvement of public facilities and
infrastructure to assist with business
locations and expansions with community
based projects.
Applications are accepted on a rolling basis.
CAP forms can be found online.
https://www.
mississippi.or
g/home-
page/busines
s-
services/com
munity-
development
/community-
services/cap/
Application
process, Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan interest used to fund
other loans.
$30,000
$1,000,000 per calendar year
County and municipal governmental
authorities may apply for the loans
for improvement of public facilities
and infrastructure to assist with
business locations and expansions
with community-based projects.
MS
Mississippi
Development
Infrastructure
Grant Program
(DIP)
Mississippi
Development
Authority (MDA)
Grant
State
Funds publicly-owned infrastructure.
Funding can be used by municipalities and
counties to assist with the location or
expansion of businesses. Usage of the funds
must be directly related to the construction,
renovation or expansion of industry. The
primary goal is Job creation.
Applications are accepted on a rolling basis.
Municipalities and counties interested in
applying for DIP funding for new or
expanded industry projects should contact
MDA's Community Services Division at 601-
359-3552. Municipalities and counties must
apply on behalf of a new or expanded
industry based on the public infrastructure
needs of the project.
https://www.
mississippi.or
g/home-
page/busines
s-
services/com
munity-
development
/community-
services/dip/
Application
process,
Grant
program
Capital, Other
None
$150,000
Usage of the funds must be directly
related to the construction,
renovation or expansion of industry.
MS
Mississippi
Drinking Water
Systems
Improvements
Revolving Loan
Fund
(DWSIRLF)
Mississippi State
Department of
Health
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents available at:
https://msdh.ms.gov/msdhsite/_static/44,0,
127,62.html.
https://msdh.
ms.gov/msdh
site/_static/4
4,0,127.html
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
MS
29
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Mississippi
Water
Pollution
Control (Clean
Water) State
Revolving Loan
Fund
(WPCRLF)
Mississippi
Department of
Environmental
Quality (MDEQ)
Loan
State
Provides low interest loan funding for water
pollution control projects, including
construction of wastewater treatment and
transportation facilities, non-point source
and stormwater pollution control programs
and estuary conservation and management
programs.
Application information is available online.
The process begins with eligible recipients
hiring a consulting engineer registered in
Mississippi.
https://www.
mdeq.ms.gov
/about-
mdeq/grants-
loans-and-
trust-funds-
available-
through-
mdeq/water-
pollution-
control-clean-
water-
revolving-
loan-fund-
wpcrlf-
program/
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loans repayments fund
additional water quality
projects or improvement
projects.
Funding level determined by
priority, number of applicants, and
total WPCRLF amount to loan.
Must be a municipality, public sewer
district, or public entity.
MS
Missouri Clean
Water State
Revolving Fund
(CWSRF)
Missouri
Department of
Natural
Resources
(DNR)
Loan
State
Traditional uses of this program are to build
or improve wastewater treatment plants for
municipalities; however, new and emerging
conservation, agricultural and urban projects
can also be funded.
Projects must apply to be on the annual
priority list. Applications can be found online.
http://www.d
nr.mo.gov/en
v/wpp/srf/wa
stewater-
assistance.ht
m
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loans repayments fund
additional water quality
projects or improvement
projects.
None
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
Applicants must demonstrate fiscal
sustainability and an ability to repay.
Political subdivision and privately-
owned and not-for-profit
organizations are also eligible
depending on the type of project.
MO
Missouri
Drinking Water
State
Revolving Fund
(SRF) Loan
Program
Missouri
Department of
Natural
Resources
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents available at:
https://dnr.mo.gov/env/wpp/srf/drinkingwat
er-assistance.htm. Projects that are
prioritized for available funding will be listed
in the annual SRF Intended Use Plan. Listing
indicates a non-binding commitment to fund
the project pending successful progress
through the SRF process by the applicant.
MO uses a portion of its set-aside to fund
subawards to community water systems to
plug abandoned wells that threaten or may
threaten the water system's source of
supply, contract with the University of
Missouri for maintenance of public water
system source water assessment and
delineation information, development of
source water protection plans, development
of brochures and signage to promote
awareness of sensitive well recharge and
watershed area.
https://dnr.rn
o.gov/env/wp
p/srf/drinking
water-
assistance.ht
m
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more. Ineligible activities include:
dam rehab, reservoirs, fire
protection, projects serving growth.
MO
30
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Montana
Drinking Water
State
Revolving Fund
(DWSRF) Loan
Program
Montana
Department of
Environmental
Quality (DEQ)
and Department
of Natural
Resources and
Conservation
(DNRC)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. MT uses a portion of its set-aside
to implement a SWP program, which
maintains and updates spatial datasets and
web-based services describing significant
potential contaminant sources to drinking
water supplies, conducts outreach and
education efforts pertaining to protecting
source waters, reviews preliminary source
water assessments, and tracks/advises on
groundwater contamination investigations
posing a risk to source waters in the state.
Application documents available at:
http://deq.mt.gov/Water/SurfaceWater/Desi
gnApprovals#collapseThree. All entities must
request that their project(s) be added to the
Priority List and Intended Use Plan. Early
notification by the applicant is essential to
get on the priority list, and a project remains
on the list until it has been completed
regardless of the funding source(s) used to
finance the project.
https://deq.rn
t.gov/Water/
Councils/Drin
kingWater
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
MT
Montana
INTERCAP
Loan Program
Montana
Department of
Commerce,
Montana Board
of Investments
Loan
State
Provides low-interest loans for a wide variety
of needs to Montana local governments. Use
of loan funds has significant flexibility, e.g.
new and used equipment and vehicles, real
property improvements, cash flow,
preliminary engineering costs, grant writing.
Application form online. Loan requests in
excess of $1,000,000 must receive Loan
Committee approval. Loan requests in excess
of $5,000,000 must receive Board approval.
http://invest
mentmt.com/
INTERCAP
Application
process, Loan
program,
Long-term
program
Capital, O&M,
Other
No upfront cost or
matching required.
Variable rate loan
program. Interest rate
through February 15,
2019 was 3.15%.
Eligible government units as defined
under 17-5-1604. Eligible projects
include those for water, wastewater
and solid waste, energy retrofits, new
and used equipment and vehicles,
preliminary engineering costs, and
grant writing.
MT
Montana
Water
Pollution
Control State
Revolving Fund
(WPCSRF)
Montana
Department of
Environmental
Quality
Loan
State
Provides at or below market interest rate
loans to eligible Montana entities for water
pollution control projects.
Applications are available from the MT
Department of Environmental Quality (DEQ).
All entities must request that their project(s)
be added to the Priority List contained in the
Intended Use Plan. This annual process
typically begins in May to identify projects
which may need SRF funding for their project
in the upcoming year.
http://deq.mt
.gov/Water/T
FA/SRF/WPCS
RF
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
The SRF loan programs
are designed to provide a
perpetual source of
financial assistance to
Montana communities.
No maximum funding level. Funds
granted based on project priority
and total available funds.
Government agency, for stormwater,
non-point source or wastewater
system improvement needs
excluding operation, maintenance
and growth development.
MT
Montana
Water
Pollution
Control State
Revolving Fund
(WPCSRF)
Montana
Department of
Environmental
Quality
Loan
State
The Water Pollution Control State Revolving
Fund (WPCSRF) Program was established for
water pollution control projects. The
program provides at or below market
interest rate loans to eligible Montana
entities.
http://deq.mt
.gov/Water/S
urfaceWater/
DesignApprov
als
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Municipal wastewater projects and
municipal and private entities non-
point source projects are eligible for
funding. Borrower must show ability
to repay the loan.
MT
National Rural
Water
Association
(NRWA) Rural
Water Loan
Fund
National Rural
Water
Association
(NRWA)
Loan
Private
Provides low-cost loans for short-term repair
costs, small capital projects or replacement
costs, or pre-development costs associated
with proposed water and wastewater
projects.
Also includes a 90-days, no interest, disaster
area emergency loans with immediate turn-
around.
Applications are online. Information can be
emailed or submitted by mail. Applicants
may also contact any State Rural Water
Association for assistance in preparing and
submitting the required documents.
http://nrwa.o
rg/initiatives/
revolving-
loan-fund/
Application
process, Loan
program
Capital, O&M
Established through a
grant from the USDA/RUS,
and repaid funds are used
to replenish the fund and
make new loans.
None
Loan amounts may not exceed
$100,000 or 75% of the total
project cost, whichever is less.
Eligible projects: Pre-development
cost for infrastructure, replacement
equipment, upgrades, maintenance
and small capital projects, energy
efficiency projects, disaster recovery
or emergency.
National
31
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
National Urban
and
Community
Forestry
Challenge
Cost-Share
Program
U.S. Forest
Service
Grant
Federal
Seeks to establish sustainable urban and
community forests by encouraging
communities to manage and protect their
natural resources. Grants are intended to
address national issues or opportunities
related to urban and community forestry.
Visit https://www.fs.fed.us/managing-
land/urban-forests/ucf/nucfac/cost-share to
check the status of the next application
period. Website says closed in 2017 check
back in 2018.
https://www.
fs.fed.us/man
aging-
land/urban-
forests/ucf/n
ucfac/cost-
share
Application
process,
Grant
program
Other
All grant funds must be
matched at least equally
(dollar for dollar) with
non-federal source funds.
Five proposals were funded in
2015, for a total of $795,447.
National
Natural
Resources
Conservation
Service (NRCS),
Conservation
Title Programs
(2018 Farm
Bill)
U.S.
Department of
Agriculture
(USDA)
Grant
Federal
The 2018 Farm Bill requires that 10% of
spending on Conservation Title programs be
directed to source water protection.
Only eligible organizations interested in
partnering with NRCS on conservation
projects can develop applications for the
RCPP competition. The lead partner for an
RCPP project is the entity that submits an
application, and if selected for an award is
ultimately responsible for collaborating with
NRCS to successfully complete an RCPP
project. Interested partners must apply
through the RCPP portal
(nrcs.my.salesforce.com). Once RCPP
projects are selected, producers and
landowners can apply to participate in
projects that cover their geographic area.
Interested producers should visit their local
USDA Service Center to see if their land is
included in the scope of any existing RCPP
projects.
https://www.
nrcs.usda.gov
/wps/portal/n
rcs/main/nati
onal/program
s/financial/rc
PP /
The 2018 Bill requires
source water protection
and matching is provided
for some projects.
Nebraska
Clean Water
State
Revolving Loan
Fund (CWSRF)
Nebraska
Department of
Environmental
Quality (DEQ)
Loan
State
Provides low interest loans and small
community matching grants to municipalities
for construction of wastewater treatment
facilities and sanitary sewer collection
systems to alleviate public health and
environmental problems.
To begin planning a wastewater system
project, the first step is to contact the NDEQ
Financial Assistance SRF Section. For more
detailed guidelines visit the DEQ website.
http://deq.ne
.gov/NDEQPr
og.nsf/OnWe
b/CWSRLF
Application
process, Fund
allocation to
states and
localities,
Grant
program,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan repayments provide
a continuing source of
funds for additional
projects.
None
Maximum funding amount varies
based on grant type. For grants,
Project Planning grants can be up
to $15,000 and Small Town grants
can be up to $250,000.
Municipalities. Maximum term of
loan is 20 years. Communities must
comply with planning requirements
and have an engineer's report
prepared by a professional engineer.
NE
Nebraska
Drinking Water
State
Revolving Loan
Fund (DWSRF)
program
Nebraska
Department of
Environmental
Quality (NDEQ),
Nebraska
Department of
Health and
Human Services,
and Nebraska
Investment
Finance
Authority (NIFA)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. NE uses a portion of its set-aside
to fund its Source Water Assessment
Program (SWAP), which works with PWSs to
develop protection actions for their drinking
water supplies, maintain Wellhead
Protection Area maps, develop of Drinking
Water Protection Management Plans,
implement BMPs aimed at reducing
groundwater nitrate levels, and public
education and outreach.
Application documents available at:
http://deq.ne.g0v/NDEQProg.nsf/OnWeb/D
WSRLF. Applicants must first complete and
submit the annual NE DWSRF Needs Survey,
which the state uses this information to
develop an Intended Use Plan, which is a
detailed prioritization of projects. Applicants
then submit a joint water/wastewater pre-
application for state and/or federal
assistance to NDEQ or the Department of
Health and Human Services and develop an
engineering report showing that present and
future conditions and environmental impacts
have been reviewed, alternative design
approaches have been identified and
assessed, and the best affordable alternative
has been selected.
http://deq.ne
.gov/NDEQPr
og.nsf/OnWe
b/DWSRLF
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs. The state asks
that possible alternative
financing sources be
identified to use in
conjunction with state
loan funds.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
NE
32
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Nevada Clean
Water State
Revolving Fund
(CWSRF)
Nevada Division
of
Environmental
Protection (DEP)
Loan
State
Provides loans for infrastructure
construction to publicly and privately owned
wastewater systems in Nevada. Loans can
also be used to control non-point sources of
water pollution.
To apply, submit two copies of facility plan to
the Office of Financial Assistance for review.
Following review, applicants must submit
CWSRF loan application.
https://ndep.
nv.gov/water
/financing-
infrastructure
/state-
revolving-
fund-
loans/clean-
water-
wastewater
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
Municipalities and interstate
agencies. Project must support the
following goals: Elimination of
surface and groundwater pollution,
protection of health, attainment of
water quality standards.
NV
Nevada
Drinking Water
State
Revolving Fund
program
(DWSRF)
Office of
Financial
Assistance
(OFA) and the
Nevada Division
of
Environmental
Protection
(NDEP)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. NV uses a portion of its set-aside
to revise and implement SWP programs,
develop and perform technical assistance
outreach and develop a strategy for dealing
with threats including pathogens, inorganics,
and nutrients.
Application documents are available at:
https://ndep.nv.gov/water/financing-
infrastructure/state-revolving-fund-
loans/how-do-i-apply. Applicants must first
submit a DWSRF Priority List pre-application,
which will then be evaluated for inclusion on
the Priority List before the applicant submits
a Loan Application Form.
https://ndep.
nv.gov/water
/financing-
infrastructure
/state-
revolving-
fund-
loans/drinkin
g-water
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
NV
New
Hampshire
Clean Water
State
Revolving Fund
(CWSRF)
New Hampshire
Department of
Environmental
Services
(NHDES)
Loan
State
Low-interest loan program that assists
communities with the planning, design and
construction of eligible water pollution
control infrastructure projects. Borrowers
are typically municipal or other local
government entities.
Must complete a pre-application. Projects
must apply to be on the annual priority list.
Applications can be accessed on website.
Pre-applications are typically due in June;
final applications are due the following
spring.
http://des.nh.
gov/organizat
ion/divisions/
water/wweb/
grants.htm
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
None
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
Must be municipal, nonprofit other
local government. For collection
system and wastewater treatment
plant plans, non-point source,
watershed protection and
restoration, and estuary
management projects.
NH
New
Hampshire
Drinking Water
State
Revolving Fund
(DWSRF)
New Hampshire
Department of
Environmental
Services
Loan
State
States can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. The State provides Local Source
Water Protection Grants to develop and
implement programs to protect existing
sources of public drinking water. Source
protection projects include: watershed
planning, delineation of protection areas,
assessment of threats to water supply
sources, implementation, source security
and conservation.
Funding applications and forms are available
at:
https://www.des.nh.gov/organization/divisio
ns/water/dwgb/capacity/dwsrf.htm
Application are accepted annually and Final
Application Checklists are provided for
various types of applicants. Pre-application
must be submitted to the State by a
designated date for that year and pre-
applications are ranked based on relative
impact of the project eligible applicants
selected for funding must than submit a full
application.
https://www.
des.nh.gov/or
ganization/di
visions/water
/dwgb/capaci
ty/dwsrf.htm
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Source Water Protection Grant
max of $20,000 (in 2017).
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
NH
33
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
New Jersey
Drinking Water
State
Revolving Fund
(DWSRF)
New Jersey
Department of
Environmental
Protection
(NJDEP):
Division of
Water Supply
and Geoscience
Loan
State
States can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Funding applications and forms are available
at: https://www.njib.gov/ Interested parties
must first file a Letter of Intent online and be
placed on the Project Priority List for
potential funding prior to applying for the
funds at the New Jersey Infrastructure Bank -
New Jersey Environmental Infrastructure
Trust for H2L0ans.
https://www.
State, nj.us/de
p/watersuppl
y/dwsjoans.
html and
https://www.
njib.gov/njeit
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs. Project
sponsors can receive a
loan for a portion of
project cost from NJEIT at
market rate and portion
at 0% from NJDEP.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more. The applicant can request
Engineering Services from the NJDEP
and one will be assigned as funds
allow.
NJ
New Jersey
Environmental
Infrastructure
Financing
Program
(NJEIFP)
State of New
Jersey
Department of
Environmental
Protection
(NJDEP)
Loan
State
Partnership between the New Jersey
Department of Environmental Protection
(NJDEP) and the New Jersey Environmental
Infrastructure Trust (Trust) to provide low
cost financing for the design, construction,
and implementation of projects that help
protect and improve water quality and help
ensure safe and adequate drinking water.
Submit applications through H2L0ans, the
State's online loan management system.
http://www.n
j.gov/dep/dw
q/mface_njeif
p.htm
Application
process, Loan
program,
Long-term
program
Capital
Utilizes two funding
sources: revenue bonds,
and combination of state
funds including state
revolving fund (SRF).
For municipalities and local
governments. Water and
environmental infrastructure
projects.
NJ
New Jersey
Environmental
Infrastructure
Financing
Program
(NJEIFP)
State of New
Jersey
Department of
Environmental
Protection
(NJDEP)
Bond
State
Partnership between the New Jersey
Department of Environmental Protection
(NJDEP) and the New Jersey Environmental
Infrastructure Trust (Trust) to provide low
cost financing for the design, construction,
and implementation of projects that help
protect and improve water quality and help
ensure safe and adequate drinking water.
Submit application through H2L0ans.
http://www.n
j.gov/dep/dw
q/mface_njeif
p.htm
Application
process, Loan
program,
Long-term
program
Capital, Other
Funding is a combination
of Federal State Revolving
Fund (SRF) capitalization
grants, as well as the
State's matching funds,
loan repayments, State
appropriations and
interest earned on such
funds.
Eligible projects include design,
construction, and implementation of
water quality projects. Eligible
applicants include municipalities and
local government utilities.
NJ
New Markets
Tax Credit
(NMTC)
Program
U.S.
Department of
the Treasury
Grant
Federal
Encourages private investment in a range of
project types in distressed areas (e.g., real
estate or business development projects).
Awards are allocated to nonprofit and
private entities based on their proposals for
distributing the tax benefits.
https://www.
cdfifund.gov/
programs-
training/Progr
ams/new-
markets-tax-
credit/Pages/
default.aspx
Application
process,
Competitive
process, One-
time
allocation
Capital
Community Development
Entities (CDEs) make loans
and investments to
businesses operating in
low-income communities
on better rates and terms
and more flexible features
than the market.
Community Development Financial
Institutions (CDFI) Fund allocates tax
credit authority to CDEs through a
competitive allocation process.
NMTC Program applicants must be
certified as CDEs by the CDFI Fund.
National
New Mexico
Clean Water
State
Revolving Fund
Loan Program
(CWSRF)
New Mexico
Environment
Department
Loan
State
Provides a source of low-cost financing for a
wide range of wastewater or stormwater
drainage projects that protect surface and
ground water. Funds may also be used for
projects that control non-point source water
pollution, such as a solid waste and septic
tank installations.
Applications accepted each spring.
http://www.n
menv.state.n
m.us/cpb/CW
SRFPage.htm
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Repayments are cycled
back into the fund and
used to pay for future
clean water projects.
Varies annually
Eligible borrowers: municipalities,
counties, water & sanitation districts,
mutual domestic water associations,
Pueblos & Tribes. Private entities are
eligible for limited projects.
NM
34
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
New Mexico
Drinking Water
State
Revolving Loan
Fund
(DWSRLF)
New Mexico
Environment
Department's
(NMED)
Drinking Water
Bureau (DWB)
and the New
Mexico Finance
Authority
(NMFA).
Loan
State
States can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. NM uses a portion of its set-aside
to organize and provide classroom trainings
and individual assistance to PWS board
members and operators which, in part,
increase PWS capacity to plan and protect
the quantity and quality of source waters. In
addition, NM uses a portion of its set-aside
to implement its Source Water and Wellhead
Protection Program, which supports an
internal team that inventories assessments
and protection plans already in place and
targets assistance to water systems that are
out of compliance with maximum
contaminant levels, are threatened by actual
contaminant sources, or are experiencing
sustainability challenges, and have an out of
date plan or no source water protection
plan.
Application documents available at:
https://www.env.nm.gov/drinking_water/wif
unding/. Applicants must first submit a
Project Interest Form and Project Interest
Form supplemental documentation to be
considered for inclusion on the Fundable
Priority List. If your project is included on a
Fundable Priority List, NMFA will invite you
to submit a DWSRLF Application.
https://www.
env.nm.gov/d
rinking_water
/wifunding/
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
NM
New York
Clean Water
State
Revolving Fund
(CWSRF)
New York State
Environmental
Facilities
Corporation
(EFC)
Loan
State
Provides interest-free or low-interest rate
financing for wastewater and water quality
improvement projects to municipalities
throughout New York State. A variety of
point source, non-point source, and national
estuary projects are eligible for financing,
including construction or restoration of
sewers and wastewater treatment facilities,
stormwater management, landfill closures,
as well as habitat restoration and protection
projects.
To be considered for CWSRF financing, a
Project Listing Form must be completed. If
the project is listed in the Annual List of the
Intended Use Plan, a complete CWSRF
Financing Application can be submitted.
Applications can be accessed on website.
https://www.
efc.ny.gov/C
WSRF
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
EFC provides both short
and long-term financing.
As borrowers repay their
loans, repayments of
principal and interest
earnings are recycled back
into the CWSRF program
to finance new projects.
Varies
Municipalities are eligible, including
Indian nations or tribes wholly or
partly within the BYS boundaries.
Non-Municipal entities can apply for
some financing. Must be a water
quality project.
NY
New York
Drinking Water
State
Revolving Fund
(DWSRF)
New York
Department of
Health and
Environmental
Facilities
Corporation
Loan
State
States can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. The State considers protection of
water quality as an eligible project.
Funding applications and forms are available
at: https://www.efc.ny.gov/DWSRFApply.
Both applicants and project must meet
eligibility requirements and applicants must
be mailed into the State by the submission
deadlines. Prior to applying for the loan
applications must be listed on the Annual
Project Priority List in the current Intended
Use Plan (IUP).
https://www.
efc.ny.gov/dri
nkingwater
and
https://www.
health.ny.gov
/environment
al/water/drin
king/water.ht
m
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more. Projects that protect water
quality are considered eligible.
NY
35
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
New York
Integrated
Solutions
Construction
(ISC) Grant
Program
New York State
Environmental
Facilities
Corporation
(EFC)
Grant
State
Grants for projects that incorporate green
infrastructure into Clean Water State
Revolving Fund (CWSRF) projects. Successful
applicants will construct projects that
remove stormwater from combined,
sanitary, or storm sewers. The proposed
project should demonstrate the value of
integrating green practices into traditional
gray infrastructure projects to provide water
quality benefits, as well as the advantages of
natural systems.
Applicants may apply for the ISC grant
through the traditional CWSRF application
process, by indicating that they are
interested in the ISC grant when they
complete the CWSRF finance application.
See eligibility requirements online.
https://www.
efc.ny.gov/IS
C
Application
process,
Grant
program
Capital, Other
Awarded projects will
receive 50% of the
construction cost of
eligible green stormwater
practices.
Total funding amount is $8 million.
ISC grant funding is available only in
conjunction with CWSRF financing.
Project must include: engineering
report, demonstrate site conditions
are suitable, include green
infrastructure that provides runoff
reduction, comply with EPA Green
Project Reserve
NY
New York Local
Government
Efficiency
(LGe) Grant
Program
New York
Department of
State (DOS)
Grant
State
Provides technical assistance and
competitive grants to local governments for
the development of projects that will
achieve savings and improve municipal
efficiency through shared services,
cooperative agreements, mergers,
consolidations and dissolutions.
Potential applicants should contact the
Department of State (DOS) for application
information. Applications can be found
online.
https://www.
dos.ny.gov/lg
/Ige/grant.ht
ml
Application
process,
Competitive
process,
Grant
program,
Long-term
program
Capital, Other
Varies
Local municipal government entities.
Project Topics include: General
Government, Government
Reorganization, City & County
Charter Revisions, Education,
Municipal Utilities, Public Safety, and
Transportation.
NY
New York
Sewage
Pollution Right
to Know
Combined
Sewer
Overflow
(CSO) Grant
New York State
Department of
Environmental
Conservation
(DEC)
Grant
State
Funding for communities to purchase and
install detection, monitoring and reporting
devices on Combined Sewer Overflows
(CSOs) to fulfill reporting requirements of
the Sewage Pollution Right to Know (SPRTK)
Law. This grant program provides funds for
municipalities to purchase and install
different types or levels of CSO detection
and notification.
Application details can be found online.
Submit questions about applications via
email.
http://www.d
ec.ny.gov/pu
bs/105337.ht
ml
Application
process,
Grant
program
Capital, Other
Individual grants are capped at
$50,000. Total funding is
$500,000.
Municipalities with CSOs. Municipal
wastewater systems must serve less
than 200,000 people, registered with
NY-ALERT, agree to use NY-ALERT to
report CSO. Funds to purchase and
install detection, monitoring and
reporting devices of CSO.
NY
New York
Wastewater
Infrastructure
Engineering
Planning Grant
(EPG)
New York State
Department of
Environmental
Conservation
(DEC) and
Environmental
Facilities
Corporation
(EFC)
Grant
State
The goal of the EPG program is to advance
water quality projects to construction and
future implementation funding through the
Clean Water State Revolving Fund (CWSRF)
program, Water Quality Improvement
Project grants, or other funding entities.
Municipalities can apply for the funding
through the Consolidated Funding
Application (CFA):
https://apps.cio.ny.gov/apps/cfa/.
http://www.d
ec.ny.gov/pu
bs/81196.ht
ml
Application
process,
Grant
program
Other
Either $30,000, $50,000 or
$100,000 grant amounts are
available based on population size.
Funds planning only, not design or
construction. Eligible applicants are
municipalities with median
household income equal or less than
$70,000 or $90,000 depending on
location.
NY
New York
Water Quality
Improvement
Project
Program
(WQIP) Grants
New York State
Department of
Environmental
Conservation
(DEC)
Grant
State
Competitive, reimbursement grant program
that funds projects that directly address
documented water quality impairments.
There are seven programs: wastewater
treatment improvement, general
wastewater treatment improvement, non-
agricultural non-point source, land
acquisition for source water protection, salt
storage, and aquatic habitat restoration.
Applications are typically available online
each spring through the Consolidated
Funding Application. Contact regional officer
for more information:
http://www.dec.ny.gov/pubs/45166.html.
http://www.d
ec.ny.gov/pu
bs/4774.html
Application
process,
Competitive
process,
Grant
program,
Long-term
program
Capital, Other
Reimbursement program.
Match requirements
amount vary depending
on projects types, range
25% to 60%.
Up to $79 million is available. Each
program has different grant/match
ratios.
Eligible for all project types:
Municipal and Soil and Water
Conservation Districts. Not-For-Profit
corporations are eligible for Aquatic
Connectivity Restoration and Land
Acquisition for Source Water
Protection only.
NY
36
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
New York
Water Quality
Management
Planning
Programs:
Clean Water
Act, Section
604(b) Funding
New York State
Department of
Environmental
Conservation
(DEC)
Grant
State
Funding is available to implement regional
comprehensive water quality management
planning activities as described in Section
604(b) of the federal Clean Water Act.
604(b) funds are to be used for water quality
management planning activities, including
tasks to determine the nature, extent and
causes of point and non-point source water
pollution problems, and to develop plans to
resolve these problems. Baseline Planning
and Statewide Planning Coordination
Programs are available for funding.
Complete applications must be submitted in
November through the New York State
Grants Gateway Grant Opportunity Portal:
https://grantsgateway.ny.gov/lntelliGrants_
NYSGG/module/nysgg/goportal.aspx. Check
online for each program eligibility.
http://www.d
ec.ny.gov/lan
ds/53122.ht
ml
Application
process,
Grant
program,
Long-term
program
Other
Next RFA expected for
2022.
$15,000 per
year (baseline
planning)
Baseline Planning maximum is
$100,000 per year. Actual amounts
for grants each year will depend
on Congressional appropriations.
Statewide Planning Coordination:
Up to $25,000 will be available
annually from 2019-2023.
Eligible applicants: NYS Regional
Planning organizations and interstate
organizations.
NY
Non-point
Source (NPS)
Implementatio
n Grants (319
Program)
U.S.
Environmental
Protection
Agency (EPA)
Grant
Federal
Under Section 319 of the Clean Water Act
(CWA), states, territories and tribes receive
grant money that supports a wide variety of
activities including technical assistance,
financial assistance, education, training,
technology transfer, demonstration projects
and monitoring to assess the success of
specific non-point source (NPS)
implementation projects.
Section 319(h) funding decisions are made
by the states. States submit their proposed
funding plans to EPA. If a state's funding plan
is consistent with grant eligibility
requirements and procedures, EPAthen
awards the funds to the state. For state-
specific application information, please
contact your state NPS coordinator
(https://www.epa.gov/nps/state-contacts-
nps-programs-your-area).
https://www.
epa.gov/nps/
319-grant-
program-
states-and-
territories
Fund
allocation to
states and
localities,
Grant
program,
Long-term
program
Capital, O&M,
Other
50% set aside for as
watershed projects funds
and 50% for NPS program
funding, (from 2013
guidelines).
$168 million total available in FY
2017.
Funding for states and tribes. NPS
management program developed
using the required guidelines to
develop.
National
North
American
Development
Bank (NADB)
Loans
North American
Development
Bank (NADB)
Loan
Federal
NADB is authorized to make loans to both
public and private sector borrowers,
operating within the United States and
Mexico. Any project, regardless of
community size or project cost, is eligible for
financing and other forms of assistance from
NADB, if it meets all three of the following
eligibility criteria: (1) The project must be
located within 100 km (62 miles) north of
the international boundary in the four U.S.
states of Texas, New Mexico, Arizona and
California. (2) It must remedy an
environmental and/or human health
problem. (3) It must pass through the Border
Environment Cooperation Commission
(BECC) certification process.
Online application is available at:
http://www.becc.org/certification-
process/apply-for-certification-financing
http://nadba
nk.org/progra
ms/loans.asp
Application
process, Loan
program
Capital, O&M,
Other
Provides financing for the
development, execution
and operation of
environmental
infrastructure projects
located in the U.S.-Mexico
border region and
certified by the Border
Environment Cooperation
Commission (BECC).
Both public and private borrowers,
operating within the US and Mexico if
criteria are met.
TX, CA,
NM, AZ
North Carolina
Clean Water
State
Revolving Fund
(CWSRF)
North Carolina
Department of
Environmental
Quality (DEQ)
Loan
State
Provides low interest loans to local
government units to fund wastewater
collection and treatment facilities as well as
programs associated with estuary and non-
point sources.
There are two funding cycles per year,
typically in March and September.
Applications and guidelines concerning the
funding process can be accessed on the
website.
http://portal.
ncdenr.org/w
eb/wi/cwsrf
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Low-interest loans,
limited amount of
principal forgiveness
loans, and 0%. Loan
repayments are used to
provide funding for future
loans.
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
For local government units. Projects:
wastewater treatment, wastewater
collection, reclaimed water,
stormwater BMPs, stream
restoration, energy efficiency at
treatment works or collection
systems. Construction must start
within 24 months.
NC
37
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
North Carolina
Drinking Water
State
Revolving Fund
(DWSRF)
North Carolina
Department of
Environmental
Quality (DEQ)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application information and documents
available at:
https://deq.nc.gov/about/divisions/water-
infrastructure/i-need-funding/application-
forms-and-additional-resources#common-
forms. NC offers in-person training for
applicants.
https://deq.n
c.gov/about/
divisions/wat
er-
infrastructure
/i-need-
funding/drink
ing-water-
state-
revolving-
fund
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
NC
North Carolina
Economic
Infrastructure
Program
North Carolina
Department of
Commerce
(NCDC), Rural
Economic
Development
Division (NCDC-
RD)
Grant
State
Funds are available to local governments to
assist with infrastructure projects that will
lead to the creation of new, full-time jobs.
Projects include upgrades or repair of
drinking water or wastewater treatment
plants or upgrades, extensions, or repair of
public water or sewer lines.
Rankings can be found on the NCDC website.
See website for application.
https://www.
nccommerce.
com/rd/rural-
grants-
programs/eco
nomic-
infrastructure
Application
process,
Grant
program
Capital
Funding varies based on county
priority (available online).
Eligible applicants are units of local
government with priority given to the
counties that have the 80 highest
rankings under N.C.G.S.143B-437.08.
NC
North Dakota
Clean Water
State
Revolving Fund
(CWSRF)
North Dakota
Department of
Public Health
(DPH)
Loan
State
Low interest loan program designed to assist
communities with a wide range of water
quality infrastructure projects.
Proposed projects must be identified on the
Project Priority List. To be included on these
lists, notify the Department of Public Health
(DPH) of intent as soon as possible.
Application packets can be obtained online
at: http://www.nd.gov/pfa/srf.html
https://deq.n
d.gov/MF/CW
SRF/
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Jointly managed by the
North Dakota Department
of Environmental Quality
(NDDEQ) and the North
Dakota Public Finance
Authority (PFA). Bond
counsel fees are the only
cost of issuance expense.
Varies
Must be a political subdivision (city,
county, township, water resource
district, etc.). Cannot be used for
O&M costs, collection lines to serve
new subdivisions, projects primarily
to serve future growth, for systems
that lack capacity, etc.
ND
North Dakota
Drinking Water
State
Revolving Fund
Program
(DWSRF)
Program
North Dakota
Department of
Environmental
Quality
(NDDEQ) and
the North
Dakota Public
Finance
Authority (PFA)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents available at:
http://www.nd.gov/pfa/srf.html. Applicant
projects must be included on the Project
Priority List (PPL). In the spring of each year,
a letter of interest is sent to all potential
DWSRF loan recipients asking for
information regarding new drinking water
projects for which they may be interested in
pursuing DWSRF assistance. Systems that
respond are provided a project ranking
questionnaire. Eligible projects for which
ranking questionnaires are returned are
ranked and included on the PPL as part of
the IUP development process. In the fall of
each year, following public review and
comment, the IUP is finalized and
subsequently included in the grant
application to the EPA. Once the IUP is
finalized, systems with projects on the PPL
may apply for DWSRF assistance.
https://deq.n
d.gov/MF/D
WSRF/
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
ND
Northern
Border
Regional
Commission
Area
Development
Fund
Northern
Border Regional
Commission
(NBRC)
Grant
Federal
Federal-State partnership for economic and
community development in northern Maine,
New Hampshire, Vermont, and New York.
The NBRC provides federal funds four areas:
Economic and infrastructure development
investments, comprehensive planning for
states, local development districts, and
general planning.
Potential applicants should contact their
state NBRC program manager to request a
pre-application package.
http://www.nbrc.gov/content/contact.
Please contact your local office for each
grant type. Information is available online.
No Appropriations for 2019.
http://www.n
brc.gov/conte
nt/program-
areas
Grant
program
Capital, Other
For economic and
infrastructure
development.
Funding varies by project type but
ranges from $200,000-$500,000
per project.
Applicants: State governments,
county and municipal government,
Indian tribes, public and nonprofit
organizations.
NH, ME,
NY, VT
38
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Ohio State
Capital
Improvement
Program (SCIP)
Ohio Public
Works
Commission
(OPWC)
Grant
State
The OPWC provides financing for local public
infrastructure improvements through the
State Capital Improvement Program (SCIP), a
grant/loan program for roads, bridges, water
supply, wastewater treatment, stormwater
collection, and solid waste disposal.
Application information is available at:
http://www.pwc.state.oh.us/Application.htm
l?m=
http://www.p
wc.state.oh.u
s/OPWCOver
view.htmlPm
Application
process,
Grant
program,
Long-term
program
Capital
Grants will cover up to
90% of project total costs
for repair/replacement,
and up to 50% for
new/expansion costs.
Loans can be provided for
up to 100% of project
costs.
There is no maximum or minimum
loan amount.
Districts may have specific
requirements. Must be government
entity. Funding for all infrastructure
programs including SCIP, LTIP,
Emergency, Small Government and
Loan Assistance/Credit
Enhancement.
OH
Ohio State
Capital
Improvement
Program (SCIP)
Ohio Public
Works
Commission
(OPWC)
Loan
State
Provides financing for local public
infrastructure improvements through the
State Capital Improvement Program (SCIP), a
grant/loan program for roads, bridges, water
supply, wastewater treatment, storm water
collection, and solid waste disposal.
Application
information:http://www.pwc.state.oh.us/Ap
plication. html?m=
http://www.p
wc.state.oh.u
s/OPWCOver
view.htmlPm
Application
process, Loan
program
Capital
Grants will cover up to
90% of project total costs
for repair/replacement,
and up to 50% for
new/expansion costs.
Loans can be provided for
up to 100% of project
costs.
None
None
Eligible applicants: counties, cities,
villages, townships, and water and
sanitary districts.
OH
Ohio Water
Pollution
Control Loan
Fund (WPCLF)
Ohio Water
Development
Authority (WDA)
Loan
State
Offers financial and technical assistance to
public or private applicants for the planning,
design, and construction of a wide variety of
projects to protect or improve the quality of
Ohio's rivers, streams, lakes and other water
resources.
Application resources can be found at:
https://epa.ohio.gov/defa/ofa#1696510029-
wpclf
https://epa.o
hio.gov/defa/
ofa#1695587
32-water-
pollution-
control-loan-
fund-wpclf-
wastewater-
collection-
and-
treatment
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Amount of funding varies based on
priority, number of applicants, and
total funds available on a given
year.
For planning, design, and
construction, stormwater projects if
they improve water quality. WPCLF
can be used by public and private
applicants for wastewater collection
and treatment, stormwater activities,
non-point source water pollution.
OH
Ohio Water
Supply
Revolving Loan
Account
Ohio
Environmental
Protection
Agency: Division
of Drinking and
Ground Waters
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Funding applications and forms are available
at:
https://epa.ohio.gov/defa/ofa#1696510030-
wsrla in the Rules/Documents section then
under WSRLA. Parties interested in a loan
should submit a project nomination which is
not a formal application but helps the State
ensure funds will be available for the project.
Nominations are accepted during the month
of August.
https://epa.o
hio.gov/defa/
ofa#1695446
10-whats-
new
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
OH
Oklahoma
Clean Water
State
Revolving Fund
(CWSRF)
Oklahoma
Water
Resources
Board (OWRB)
Loan
State
Low-interest loan program to assist
communities with municipal
wastewater/stormwater infrastructure
construction projects and other pollution
control projects.
Applications are accepted at any time during
the year. Must submit fee, loan application,
engineering report/planning documents, and
any necessary environmental information
documents.. Applications are available
online.
http://www.o
wrb.ok.gov/fi
nancing/loan/
cwsrfloans.ph
P
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Can be used for previously
incurred engineering
expenses if cost is directly
associated with
engineering study or
report.
2019 Fundable projects amounts
range from $100,000 to
$11,000,000.
For local government agencies,
school districts, and districts formed
under title 82.
OK
39
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Oklahoma
Drinking Water
State
Revolving Fund
(DWSRF)
Oklahoma
Department of
Environmental
Quality (DEQ)
and Oklahoma
Water
Resources
Board (OWRB)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents can be found at
https://www.owrb.ok.gov/financing/loan/dw
srfloans.php. Applicants must first submit a
Request for Placement Letter, which is used
to establish a project's eligibility for funding,
and priority score which is then used for
placement on the Project Priority List (PPL).
Projects are ranked, in order of their priority
score, but funded based on the readiness to
proceed as defined in the Intended Use Plan
(IUP). OK uses a portion of its set-aside to
conduct source water assessments and to
complete Source Water Assessment and
Protection Plans (SWAPs) for drinking water
suppliers in the state.
https://www.
deq.ok.gov/w
ater-quality-
division/publi
c-water-
supply/dwsrf/
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
OK
Oklahoma
Financial
Assistance
Loan Program
Oklahoma
Water
Resources
Board (OWRB)
Loan
State
A low-interest loan program to assist eligible
entities with projects related to water and/or
sewer system improvements or for the
refinancing of existing debt obligations
incurred by an eligible entity for these
projects. Eligible projects include
water/wastewater facility expansion,
replacement, improvement, and/or repair,
dams, reservoirs, and other water storage
projects, floodplain restoration and stream
bank stabilization, storm sewer and drainage
improvements.
Applications are accepted at any time during
the year. Applicants must submit a Loan
Application and fee. Applications are
available online at:
http://www.owrb.ok.gov/financing/faforms.
php
http://www.o
wrb.ok.gov/fi
nancing/loan/
bondloans.ph
P
Application
process, Loan
program,
Long-term
program,
Non-
competitive
process
Capital, O&M,
Other
Loan may be issued up to
30 years, specifically for
water project assistance.
Funding can be used to
refinance debt.
Eligible entities: Counties, towns and
municipalities, Public Works
Authorities, School Districts, Districts
formed under title 82.
OK
Oklahoma
Rural
Economic
Action Plan
(REAP) Grant
Oklahoma
Water
Resources
Board (OWRB)
Grant
State
To assist eligible entities with a population of
7,000 or less. Eligible projects include sewer
line construction or repair, storm or sanitary
sewer projects, water line construction or
repair, water treatment systems, water
acquisition, water distribution or recovery
systems, and other water or wastewater
projects. Entities with a population less than
1,750, unincorporated areas of less than 525
taps or school districts with less than 525
students are given priority.
Closed funding cycle program. Application
and pertinent attachments must be received
by the first business day in September to be
scored, ranked and placed on a priority list.
Applications are available online at:
http://www.owrb.ok.gov/forms/FAforms/RE
APGrantPacket.pdf
http://www.o
wrb.ok.gov/fi
nancing/grant
/reapgrants.p
hp
Application
process,
Grant
program,
Long-term
program
Capital
No matching
requirement. This is a
point-based program.
None
$150,000
For cities or townships with a pop.
less than 7,000. Rural water districts
with less than 525 non-pasture
customers. Entities: Counties, towns,
municipalities, Public Works
Authorities, School districts, districts
from Title 82.
OK
Oregon Clean
Water State
Revolving Fund
(CWSRF)
Oregon
Department of
Environmental
Quality (DEQ)
Loan
State
Provides below-market rate loans for the
planning, design and construction of various
water pollution control activities. Eligible
projects include: planning and design,
wastewater treatment facilities, recycled
water distribution, interceptors, force mains,
and pumping stations, l/l correction,
overflow correction, sewer
replacement/rehabilitation, stormwater
management, planning.
Applications are accepted on a rolling basis.
To apply, contact DEQ's regional project
officers at 503-229-LOAN, or visit the
website.
http://ww
w.oregon.gov
/deq/wq/cws
rf/Pages/defa
ult.aspx
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
$37,256,625 total was provided in
project assistance for state fiscal
year 2017.
All public agencies and tribes are
eligible.
OR
40
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Oregon Safe
Drinking Water
Revolving Loan
Fund or
Drinking Water
State
Revolving Fund
Oregon Health
Authority
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. The set-aside allows for up to
$100,000 loans for source water assessment
(SWA) implementation activities, including
SWP land acquisition. The State may also
provide grants up to $30,000 or technical
support in the area of SWP. Funds must be
spent within 2 years of contract execution.
Interested parties must submit a Letter of
Interest (LOI) that includes details about the
drinking water projects including water
supply, water quality problem(s), water
system's finances and readiness-to-proceed,
project solution and cost. The LOI is
evaluated and prioritized and added to a
Project Priority List (PPL). LOI can be
submitted at anytime and the online guide is
available at:
http://www.orinfrastructure.org/LOI-Form/.
The State may also provide grants up to
$30,000 or technical support in the area of
SWP. Funds must be spent within two years
of contract execution.
https://www.
oregon.gov/o
ha/PH/Health
yEnvironment
s/DrinkingWa
ter/SRF/Pages
/index.aspxht
tps://www.or
egon.gov/oha
/PH/HEALTHY
ENVIRONME
NTS/DRINKIN
GWATER/SRF
/Documents/
SP-lnfo.pdf
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Drinking Water Source Protection
Fund (DWSPF): $100,000 per
project loan and $30,000 per
eligible system in the form of a
grant.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
OR
Oregon
Water/Waste
water
Financing
Program
Oregon
Infrastructure
Finance
Authority (IFA)
Loan
State
Funds the design and construction of public
infrastructure needed to ensure compliance
with the Safe Drinking Water Act or the
Clean Water Act. Projects: construction
improvement or expansion of drinking
water, wastewater, or stormwater systems,
water source treatment, stormwater
systems, etc.
Contact IFA regional coordinator to begin
the application process; project proposals
are accepted throughout the year. Locate
Regional Development Officer based on the
county location of the project:
http://www.oregon4biz.com/directory.php?
d=l.
http://www.o
rinfrastructur
e.org/lnfrastr
ucture-
Programs/W
W/
Application
process,
Grant
program,
Loan
program,
Long-term
program,
Non-
competitive
process
Capital
Loans and grants are
determined by financial
analysis. Loans may be
issued for up to 25 years.
None
$10,000,000 per project through a
combination of direct and/or bond
funded loans. Grant awards up to
$750,000 may be awarded based
on a financial review.
Eligible: Public entities including
ports, and special districts as defined
in ORS 198.010.
OR
Partners for
Fish and
Wildlife
U.S. Fish and
Wildlife Service
Public-
private
partner
ship
Federal
Provides technical and financial assistance to
private landowners to restore fish and
wildlife habitats on their lands via
cooperative agreements.
Contact the Fish and Wildlife Service directly;
contact information is available at
https://www.fws.gov/partners/.
https://www.
fws.gov/partn
ers/
Other
Estimated $52 million in FY2017
(funding levels indicate total
program funding; about one half is
available for project funding).
VA
Pennsylvania
Clean Water
State
Revolving Fund
(CWSRF)
Pennsylvania
Infrastructure
Investment
Authority
(PENNVEST),
Pennsylvania
Department of
Environmental
Protection
Loan
State
Offers low interest loans with flexible terms
to assist a variety of borrowers that include
local governments, municipalities, and
privately owned entities and to establish
partnerships to leverage other funding
sources. Projects: construction and
maintenance of wastewater treatment
facilities, stormwater management projects,
non-point source pollution controls, and
watershed and estuary management.
Online Funding Request is a fully automated
on-line system that allows applicants to
electronically process data and perform
required actions during the application
process for requesting funds from
PENNVEST. Apply at:
http://www.pennvest.pa.gov/Services/Pages
/Apply-Online.aspx
http://www.p
ennvest.pa.go
v/lnformation
/Funding-
Programs/Pag
es/Clean-
Water-State-
Revolving-
Fund.aspx#.V
zs5qeSgbsl
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Low interest flexible term
loans. Repayments may
be used to fund future
projects.
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
Entities: Local government,
municipalities, privately owned
entities.
PA
Pennsylvania
Drinking Water
State
Revolving Fund
(DWSRF)
Program
Pennsylvania
Infrastructure
Investment
Authority
(PENNVEST) and
Pennsylvania
Department of
Environmental
Protection (DEP)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. PA uses set-aside to fund GW
monitoring networks, source water GIS, data
management, river alert network, and
regional SWP plan.
Funding applications are received and
processed through PENNVEST's on-line
system, available at:
https://www.pennvest.pa.gov/Services/Page
s/Apply-Online.aspx. Applicants must have a
consultation with DEP and PENNVEST staff
before completing or submitting an
application.
https://www.
dep.pa.gov/B
usiness/Wate
r/CleanWater
/Infrastructur
eFinance/Pag
es/State-
Revolving-
Fund.aspx
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
PA
41
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Pennsylvania
Industrial
Development
Authority
(PIDA)
Pennsylvania
Department of
Community &
Economic
Development
(DCED)
Loan
State
Provides low-interest loans and lines of
credit for eligible businesses that commit to
creating and retaining full-time jobs and for
the development of industrial parks and
multi-tenant facilities.
Loan applications are packaged by a CEDO
that services the county the business is or
will be located in. The CEDO will work with
the applicant to determine whether or not
the PIDA loan program can assist with
financing the needs of the business and will
discuss with the applicant in detail how the
application process works.
http://www.n
ewpa.com/pr
ograms/penn
sylvania-
industrial-
development-
authority-
pida/#.Vzs9q
OSgbsl
Application
process, Loan
program,
Long-term
program
Capital, Other
Generally a 50% match is
required. Loan approval is
contingent on meeting
program underwriting and
collateral requirements.
Maximum Machinery and
equipment loans is $1,500,000.
Maximum working capital term
loans and lines of credit is
$100,000.
vdi iety of industries are eligible,
projects can be land and building
acquisitions; construction and
renovation, machinery and
equipment, accounts receivable lines
of credit, industrial parks,
multitenant facility projects.
PA
Pisces
Foundation:
Water Grant
Pisces
Foundation
Grant
Private
Responds to water supply and quality
challenges by supporting innovative
approaches to durably protect the nation's
water resources. The Foundation's goal is to
help spur a transition from a system that
manages quality and supply in isolation with
a more powerful, integrated paradigm. This
new, modern approach will place water at
the center of community "leveraging it to
green communities, support nature, and
sustain farms and business."
The Pisces Foundation does not accept
unsolicited grant proposals.
https://pisces
foundation.or
g/what-we-
do/water/
Application
process,
Grant
program,
Long-term
program
Capital, Other
Seek out collaborations
with other funders to
increase collective impact
and accelerate work.
Leverage for other
funding.
Funding varies but water grants
awards range from $25,000 to
$255,000.
CA
Planning
Assistance to
States (PAS)
U.S. Army Corps
of Engineers
(USACE)
Public-
private
partner
ship
Federal
The U.S. Army Corps of Engineers (USACE)
can provide states, local governments, other
non-Federal entities, and eligible Native
American Indian tribes assistance in the
preparation of comprehensive plans for the
development, utilization, and conservation
of water and related land resources. Typical
studies are only at the planning level of
detail; they do not include detailed design
for project construction. The program can
encompass many types of studies dealing
with water resources issues. Types of studies
conducted in recent years under the
program include the following: water
supply/demand, water conservation, water
quality, environmental/conservation,
wetlands evaluation/restoration, dam
safety/failure, flood damage reduction,
coastal zone protection, and harbor
planning. The study sponsor has the option
of providing in-kind services for its share of
the study cost.
The process for PAS investigations begins
after a state, regional, local government, or
Native American Indian tribe requests USACE
assistance under the program. The USACE
will work with the requesting organization to
develop a scope of work and assemble the
appropriate study team for the effort being
requested. Once a scope of work has been
developed, a cost sharing letter agreement
will be prepared and sent to the sponsor for
their signature. Once the both parties have
signed the agreement, the study may begin,
subject to the availability of both Federal and
local funding.
http://www.n
ae.usace.arm
y.mil/Mission
s/Public-
Services/Plan
ning-
Assistance-to-
States/
Application
process, One-
time
allocation
Other
Efforts under this program
are cost shared on a 50%
Federal - 50% non-
Federal basis. The study
sponsor has the option of
providing in-kind services
for its share of the study
cost.
USACE will work with the requesting
organization to develop a scope of
work.
National
Planning
Program and
Local Technical
Assistance
Program
U.S. Economic
Development
Administration
(EDA)
Grant
Federal
Assists eligible recipients in developing
economic development plans and studies
designed to build capacity and guide the
economic prosperity and resiliency of an
area or region. The Local Technical
Assistance program strengthens the capacity
of local or State organizations, institutions of
higher education, and other eligible
recipients to undertake and promote
effective economic development programs
through projects such as feasibility studies
and impact analyses.
Applications are accepted on a continuing
basis and processed as received. Contacts
vary by region.
https://www.
eda.gov/fundi
ng-
opportunities
/
Application
process,
Grant
program,
Long-term
program
Other,
Outreach
EDA seeks to fund
applications that use
public and private sector
resources, and/or
leverage complementary
investments by other
government/public
entities and/or nonprofits.
$300,000 with a matching
requirement.
Eligible recipients include, but are not
limited to, district organizations and
tribes.
National
42
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Pre-Disaster
and Flood
Mitigation
Assistance
Grant
Programs
California Office
of Emergency
Services
Grant
State
Funds are provided from FEMA to
California's Office of Emergency Services.
Applications will only be considered based
on FEMA-approved methodology to
demonstrate cost-effectiveness.
NOI must be completed and applicants must
have a FEMA approved mitigation plan.
https://www.
caloes.ca.gov
/cal-oes-
divisions/haza
rd-
mitigation/pr
e-disaster-
flood-
mitigation
Application
process, Fund
allocation to
states and
localities,
Grant
program
Capital,
Compliance,
Other
$160 million total (FY2019)
States and tribes are eligible to apply
for funding.
CA
Pre-Disaster
Mitigation
Program
(PDM)
U.S. Federal
Emergency
Management
Agency (FEMA)
Grant
Federal
Designed to assist States, U.S. Territories,
Federally-recognized tribes, and local
communities in implementing a sustained
pre-disaster natural hazard mitigation
program. The goal is to reduce overall risk to
the population and infrastructure from
future hazard events, while also reducing
reliance on Federal funding in future
disasters.
Local governments are eligible subapplicants
and can sponsor applications on behalf of
homeowners to submit to the Applicant.
Sub-applicants submit mitigation planning
and project sub-applications to their State
during the open application cycle. After
reviewing planning and project applications
to determine if they meet the program's
requirements, the Applicants (i.e.,. States,
U.S. Territories, or Federally-recognized
tribal governments) prioritize and forward
the planning and project applications in a
PDM grant application to FEMA. Locals
should contact their State Hazard Mitigation
Officer (SHMO) or Federally-recognized
tribal/local government official to obtain
detailed information on the PDM application
process.
https://www.
fema.gov/pre
-disaster-
mitigation-
grant-
program
Application
process,
Competitive
process,
Grant
program
Capital, Other
Federal funding is
available for up to 75% of
the eligible activity costs.
Small, impoverished
communities may be
eligible for up to a 90%
Federal cost share.
$50 million total. Each State and
Territory receives $575,000. $15
million is set aside for Federally-
recognized tribes to receive
$575,000 per tribe. No applicant
may receive more than 15%, or
$37,380,000 of the appropriated
PDM funding.
Eligible: States, US Territories,
Federally Recognized Tribes, Local
governments.
National
Project
Development
Assistance
Program
(PDAP)
U.S. EPA/
Border
Environmental
Cooperation
Commission
(BECC)
Grant
Federal
Provides grant funds, for project
development and design. Funds public water
and wastewater infrastructure projects
identified through a program-specific
prioritization process.
Online application:
http://www.becc.org/certification-
process/apply-for-certification-financing.
http://www.b
ecc.org/fundi
ng-
programs/tec
hnical-
assistance/pd
ap
Application
process, Fund
allocation to
states and
localities,
Grant
program
Capital
Can be combined with
NADB loans to meet
funding. If received the
grant are eligible to
receive technical
assistance through PDAP
to support development
activities aimed at
facilitating successful
implementation.
Varies.
Must be high-priority municipal
drinking water and wastewater
infrastructure projects located within
100 Km of the US -Mexico Boarder.
TX, NM,
AZ, CA
Project
Modifications
for
Improvement
of the
Environment
(CAP Section
1135)
U.S. Army Corps
of Engineers
(USACE)
Public-
private
partner
ship
Federal
This program provides for modifications in
the structures and operations of water
resources projects constructed by the U.S.
Army Corps of Engineers (USACE) to improve
the quality of the environment. Additionally,
the USACE may undertake restoration
projects at locations where an existing
USACE project has contributed to the
degradation. Additional program
information:
http://www.lrl.usace.army.mil/Portals/64/do
cs/Outreach/lnformation/1135.pdf
Go to
http://www.usace.army.mil/Locations/; look
for your state and district to find your local
contact person. State or local government
officials should consult the nearest USACE
District Engineer regarding specific problems
and the possibility of remedial action under
this program.
http://www.u
sace.army.mil
/
Long-term
program,
Non-
competitive
process
Capital, Other
Formal assurance of local
cooperation must be
furnished by a local
sponsoring agency. The
local sponsor must be a
public agency or a
nonprofit environmental
organization. Private
interests may also qualify.
Sponsors must agree to
items on webpage.
Initial study is 100% federally
funded up to $100,000. The
remainder of the study phase is
cost shared 50% Federal and 50%
non-Federal. The design and
implementation of the project are
cost shared on a 75% Federal, 25%
non-Federal basis. The non-Federal
portion may be made up of a
mixture of cash, in-kind
contributions, and Lands,
Easements, Rights of-way,
Relocation, and Disposal areas
(LERRDs). Each project is limited to
a Federal Cost of no more than
$10,000,000, and the national
program limit for these projects is
$25,000,000 per year.
A study of a prospective Section 1135
will be initiated after receipt of a
written request from an authorized
sponsoring agency & provided
Federal funds are available. Primary
objective is to modify existing USACE
projects to restore ecosystem
habitat.
National
43
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Proposition 1
(Water
Quality,
Supply, and
Infrastructure
Improvement
Act of 2014)
California
Department of
Water
Resources
(DWR)
Grant
State
Funds are allocated throughout 12
hydrologic region-based Funding Areas in
the state of California. The various grant
programs under Proposition 1 include:
Disadvantaged Communities, Planning, and
Implementation Programs.
Proposal are accepted via the website.
https://water.
ca.gov/Work-
With-
Us/Grants-
And-
Loans/IRWM-
G rant-
Programs/Pro
position-1
Application
process,
Competitive
process,
Grant
program
Capital, Other
An average local cost
share of not less than 50%
of the total project costs
in a proposal is required.
$510 million
The Integrated Regional Water
Management (IRWM) region must
have been accepted into the IRWM
Grant Program through the Region
Acceptance Process. Funding can be
allotted to: public agencies, NGO,
utilities, tribes, and municipal water
companies.
CA
Public
Assistance (PA)
Grant Program
U.S. Federal
Emergency
Management
Agency (FEMA)
Grant
Federal
Provides federal assistance to government
organizations and certain private nonprofit
(PNP) organizations following a Presidential
disaster declaration. Through the program,
FEMA provides supplemental federal
disaster grant assistance for debris removal,
life-saving emergency protective measures,
and the repair, replacement, or restoration
of disaster-damaged publicly owned
facilities, and the facilities of certain PNP
organizations. The PA Grant Program also
encourages protection of these damaged
facilities from future events by providing
assistance for hazard mitigation measures
during the recovery process.
If a State, Territorial, Tribal, or local
government entity or PNP wishes to seek PA
funding, it must first submit a Request for
Public Assistance (RPA) to FEMA, through
the Recipient, within 30 days of the
respective area being designated in the
declaration. The RPA (FEMA Form 90-49) is
the form to apply for the PA Program; FEMA
also refers to it as a pre-application.
https://www.
fema.gov/pub
lic-assistance-
local-state-
tribal-and-
non-profit
Application
process, Fund
allocation to
states and
localities,
Grant
program
Capital, Other
25% non-Federal share.
May not duplicate
benefits with insurance.
The Recipient determines
how the non-federal
share (up to 25%) is split
with the sub-recipients
(eligible applicants).
For state, tribal, territorial, and local
governments and certain types of
PNP organizations. For response and
recovery from major disasters or
emergencies.
National
Public Works
Board -
Emergency
Loan Program
State of
Washington -
Department of
Commerce
Loan
State
Funds the repair, replacement,
rehabilitation, or reconstruction of eligible
systems to bring them up to current
standards for existing users.
Eligible applicants: Counties, cities, special
purpose districts, and quasi-municipal
organizations (water, sanitary sewer,
stormwater, roads, streets, bridges, solid
waste, and recycling facilities). School
districts, port districts, or tribes are
ineligible, per statue. Application cycle is
open until appropriated funds are
exhausted.
http://www.p
wb.wa.gov
Application
process, Loan
program
Other
20-year loan term or life
of the improvement,
whichever is less. Interest
rates vary.
$1 million per jurisdiction per
biennium.
Eligible project: A public works
project made necessary by a natural
disaster or an immediate an
emergent threat to the public
health/safety due to unforeseen or
unavoidable circumstances. Must
demonstrate financial need through
inadequate local budget.
WA
Public Works
Board
Construction
Loan Program
Washington
State
Department of
Commerce
Loan
State
Low-interest loans for local governments to
finance public infrastructure construction
and rehabilitation. Eligible projects must
improve public health and safety, respond to
environmental issues, promote economic
development, or upgrade system
performance.
Contact: Cecilia Gardener rExecutive Director
cecilia.gardener@commerce.wa.gov 360-
725-3166
http://www.p
wb.wa.gov
Application
process, Loan
program
Capital, O&M
Program on hold until capital
budget is passed.
To be eligible must be a public
infrastructure project/local
government.
WA
Puerto Rico
Drinking Water
Treatment
Revolving Loan
Fund
Puerto Rico
Department of
Health (DOH)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for SWP activities
including: purchase land or conservation
easements; implement SWP petition
programs or incentive-based measures.
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
PR
44
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Region 1
Healthy
Communities
Grant Program
U.S.
Environmental
Protection
Agency (EPA)
Grant
Federal
EPA Region l's main competitive grant
program to work directly with communities
to reduce environmental risks to protect and
improve human health and the quality of life.
Apply online. If an applicant is located in
Maine, New Hampshire, or Rhode Island and
is selected to submit a full proposal under
the Healthy Communities Grant Program,
the applicant must submit one copy of their
complete application to their State contact
at the same time of submission to EPA. For
more information on the process a particular
State requires to be followed, an applicant
should contact the office or official
designated in their State. Connecticut,
Massachusetts, and Vermont have chosen
not to participate in the intergovernmental
review process.
http://www3.
epa.gov/regio
nl/eco/uep/h
cgp.html
Application
process,
Competitive
process,
Grant
program
Other,
Outreach
$25,000; total available funding is
$250,000.
Must be located in New England.
MA, CT,
NH, Rl
ME, VT
Regional
Conservation
Partnership
Program
(RCPP)
U.S.
Department of
Agriculture
(USDA)- Natural
Resources
Conservation
Service (NRCS)
Grant
Federal
Regional Conservation Partnership Program
(RCPP) provides an opportunity for partners
to scope a five year project in partnership
with NRCS to enhance and accelerate
conservation efforts, innovation and locally-
driven solutions. Partnering organizations
design, promote, implement, and evaluate
the project outcomes in partnership with
NRCS programs. RCPP projects areas include
agricultural conservation easement program
(ACEP), environmental quality incentives
program (EQIP), conservation stewardship
program (CSP), and health forests reserve
program (HFRP).
Application forms available online.
https://www.
nrcs.usda.gov
/wps/portal/n
rcs/main/nati
onal/program
s/financial/rc
PP /
Application
process,
Grant
program,
Long-term
program
Other
Federal resources should
be leveraged to at least
double the total
investment. RCPP funding
is split between two
funding pools - Critical
Conservation Areas and
state/multistate.
Applicants must match or
exceed the federal award.
In all, NRCS plans to invest
approximately $220 million in
projects across the country. See
list of RCPP projects by state
(available online).
Eligible partners: Agriculture or
silviculture producer associations,
farmer coops, or other producers,
state or local government, tribes,
municipal water entities, water and
irrigation districts and conservation-
driven nongovernmental
organizations, etc.
National
Regional
Water Plan
Seed Grant
Funds
Georgia
Environmental
Protection
Division (EPD)
Grant
State
Georgia EPD has developed a grant program
to provide funding to eligible recipients for
projects related to water quality and
nutrient management, with a focus on the
implementation of Regional Water Plans.
Interest parties must complete and submit
the application form available at
https://epd.georgia.gov/regional-water-plan-
seed-grant-funds.
https://epd.g
eorgia.gov/re
gional-water-
plan-seed-
grant-funds
Application
process,
Competitive
process,
Grant
program
Capital,
Other,
Outreach
Award recipient must
provide a minimum match
amount of 40% of the
total project cost. Of that
40%, a minimum of 10%
of the total project cost
must be in the form of a
cash expenditure with the
remaining amount in in-
kind services.
None
$75,000
Applicants may include local
governments, regional commissions,
resource conservation districts, and
schools. Applicants must have a
Qualified Local Government Status.
The application is available online.
GA
Rhode Island
Clean Water
State
Revolving Fund
(CWSRF)
Rhode Island
Infrastructure
Bank (RIIB),
Rhode Island
Department of
Environmental
Management
(RIDEM)
Loan
State
This program provides below market rate
loans for the construction and upgrade of
wastewater collection systems & treatment
facilities, stormwater pollution prevention &
treatment facilities, non-point source
pollution best management practices and
other water pollution abatement/water
quality protection activities.
Projects must apply to be on the annual
priority list. Applications can be found online.
http://www.d
em.ri.gov/pro
grams/water/
finance/state-
revolving-
fund.php
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
RIDEM is partnered with
RIIB for the CWSRF. The
Interceptor Bond Fund
provides 50% matching
grants up to $500,000 for
the construction of
interceptor sewers.
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
Must be a municipality or quasi-
public agency.
Rl
45
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Rhode Island
Drinking Water
State
Revolving Fund
(DWSRF)
Rhode Island
Department of
Health (DOH)
Loan
State
States can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Funding applications and forms are available
at: https://www.riib.org/dwsrf. In order to
receive a loan, the interested party must
submit a proposal to the State and be placed
on the Rl DOH Project Priority List.
http://health.
ri.gov/progra
ms/detail.php
?pgm_id=127
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
Rl
Rhode Island
Water
Pollution
Control
Revolving Fund
(RIWPCRF)
Rhode Island
Infrastructure
Bank (RIIB)
Loan
State
The fund has been used to finance projects
not meeting the requirements of federal
programs. Eligible projects include purchase
of watershed lands, property surveys and
appraisals, water supply system
management plans, and other physical
improvements that directly protect public
drinking water supplies.
Applications for funds must first be
submitted to the Rhode Island Water
Resources Board, which verifies project
eligibility, and then a written request for
funds can be submitted to the Rhode Island
Infrastructure Bank.
https://www.
riib.org/RIWP
CRF
Application
process, Loan
program,
Long-term
program
Capital, Other
Loans are repaid over
time and the recycled
funds are used to make
additional loans.
Loan amounts vary.
Eligible applicants: public drinking
water suppliers.
Rl
Rivers, Trails
and
Conservation
Assistance
(RTCA)
Program
U.S.
Department of
the Interior —
National Park
Service (NPS)
Grant
Federal
Assists community-led natural resource
conservation and outdoor recreation
initiatives. RTCA staff provide guidance to
communities on conserving waterways,
preserving open space, and developing trails
and greenways.
Consult with community partners to build a
broad base of support for the project idea.
Review the application
(https://www.nps.gov/orgs/rtca/upload/RTC
A_Application_2019_Final.pdf). Contact NPS
prior to the application deadline to inform
them of intent to apply and obtain
assistance. Application must include
commitment letters from three or more
project partners, site location map,
completed form, and optional supplemental
information.
https://www.
nps.gov/orgs/
rtca/apply.ht
m
Application
process,
Competitive
process,
Grant
program
Other,
Outreach
Assistance includes
defining project vision and
goals, setting priorities,
identifying funding
strategies, designing
outreach strategies, and
more.
Eligible entities: State and local
agencies, tribes, nonprofits,
organizations, or citizen groups.
National Parks and Federal Agencies
may apply in partnerships with other
local organizations.
National
Rockefeller
Foundation
Environmental
Impact Bond
(EIB)
Rockefeller
Foundation
Bond
Private
An Environmental Impact Bond (EIB) is an
innovative financing tool that uses a Pay for
Success (PFS) approach to provide up-front
capital for environmental programs, either
to pilot a new approach whose performance
is viewed as uncertain or to scale up a
solution that has been tested on a small
scale. In its most basic form, private
investors participating in a PFS model pay
the upfront costs for deploying these
environmental solutions. Following
deployment and program evaluation, the
payorffl, the public agency or private
institution that benefits from these
solutions, makes a repayment to investors
linked to the achievement of agreed-upon
outcomes of the program (such as avoided
stormwater runoff).
https://neighborly.com/issuers/profile/proje
ct-type. The Request for Proposal is now
closed.
http://www.q
uantifiedvent
ures.com/roc
kefeller-eib
Application
process,
Competitive
process, One-
time
allocation
Capital
Partnered with
Rockefeller Foundation,
Quantified Ventures, and
Neighborly. Issues EIB.
This effort aims to
demonstrate the
scalability of the EIB
model and develop the
EIB market.
Varies by project.
Funds are for green infrastructure
and resilience projects. For two
municipalities. Must be a County or
municipal government, utility, water
or sewer authority, or private sector
serving in a function related to
infrastructure. Must have good
credit.
National
Rural Business-
Cooperative
Service -
Community
Economic
Development
U.S.
Department of
Agriculture
(USDA)
Loan
Federal
USDA's Community Development Programs
include programs, technical help and that
help rural cities and areas to realize their
strategic, long-term economic development
goals.
https://www.
rd.usda.gov/a
bout-
rd/agencies/r
ural-business-
cooperative-
service
Loan
program,
Long-term
program
Capital,
Other,
Outreach
Promotes partnerships to
provide "must needed"
money to rural areas.
Projects that help provide capital,
training, education, and
entrepreneurial skills that can help
those in rural areas start and grow
businesses or find jobs in agricultural
markets.
National
46
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
S.D. Bechtel Jr.
Foundation:
Environment
Grant
S.D. Bechtel Jr.
Foundation
Grant
Private
The Foundation seeks to advance the
transition to more sustainable and effective
approaches to water and land management
by investing in grantees that develop and
scale innovative models; expand the
knowledge base; ground resource
management in best practice; and support
sound policies.
Proposals are accepted by invitation only.
Foundation sunsets in 2020, have developed
grant resources to be used when close.
http://sdbjrfo
undation.org/
environment/
Application
process,
Grant
program
Capital, Other
Projected program investment
budget for 2017 was $148 million.
Foundation sunsets in 2020. Only
accepts and responds to invited
proposals. Financial Analysis
Template is required for all capital,
core support, and scaling proposals.
CA
Sanitation
Facilities
Construction
(SFC) Program
U.S.
Department of
Health and
Human Services
(DHHS )- Indian
Health Service
(IHS)
Public-
private
partner
ship
Federal
Provides engineering, technical, and financial
assistance to Native tribes and Alaska Native
villages for cooperative development and
continued operation of safe water,
wastewater, and solid waste systems and
related support facilities.
More information on technical and financial
assistance is available at
htt ps ://www. i hs.gov/dsfc/resou rces/
General criteria scoring criteria includes
eight factors.
https://www.i
hs.gov/dsfc/
Long-term
program
Other
Technical assistance can
be enhanced by the ability
of the IHS O&M technical
assistance provider to find
and leverage available
resources to satisfy
identified requirements.
Varies annually
Must be a recognized tribe.
National
Section 108
Loan
Guarantee
Program
U.S.
Department of
Housing and
Urban
Development
(HUD)
Loan
Federal
Allows future Community Development
Block Grant (CDBG) allocations to be used to
guarantee loans for neighborhood
revitalization projects, including construction
and installation of public facilities and
infrastructure. Section 108-guaranteed
projects can incorporate green infrastructure
into their design and construction.
Public entities wishing to apply for Section
108 Loan Guarantee Program assistance are
advised to contact HUD in advance for
guidance in preparing an application. Public
entities may contact either the Community
Planning and Development staff at the
appropriate local HUD Field Office or the
Section 108 office in Washington at (202)
402-4202.
https://www.
hudexchange.
info/program
s/section-
108/
Application
process, Loan
program,
Long-term
program
Capital, Other
Leverage CDBG Grants.
Loans typically range from a few
hundred thousand to several
million dollars.
Eligible applicants include state and
local governments. Projects can
include: economic development,
housing rehabilitation, public
facilities, and other physical
infrastructure projects, including
those to increase resilience to natural
disasters.
National
Small
Community
Wastewater
Treatment
Program
Minnesota
Public Facilities
Authority (PFA)
Loan
State
Administered by the Minnesota Public
Facilities Authority (PFA), the program
provides technical assistance grants and
construction grants and loans for public
subsurface sewage treatment systems.
Contact PFA staff before submitting an
application.
https://mn.go
v/deed/gover
nment/public
facilities/fund
s-
programs/sm
allcommunity
wastewatertr
eatmentprogr
am.jsp
Application
process, Loan
program,
Long-term
program,
Non-
competitive
process
Capital,
Compliance
None
$60,000
For communities to replace non-
complying septic systems and
straight pipes with new individual or
cluster subsurface sewage treatment
systems (SSTS) that will be publicly
owned, operated and maintained.
MN
Small Flood
Damage
Reduction
Projects
U.S. Army Corps
of Engineers
(USACE)
Public-
private
partner
ship
Federal
Section 205 of the 1948 Flood Control Act
authorizes the U.S. Army Corps of Engineers
(USACE) to study, design, and construct
small flood control projects in partnership
with non-Federal government agencies, such
as cities, counties, special authorities, or
units of state government. (The website
provided is an example from one USACE
district.)
Identify USACE district and point of contact
for requesting assistance at
http://www.usace.army.mil/Locations/.
http://www.n
ae.usace.arm
y.mil/Mission
s/Public-
Services/Cont
inuing-
Authorities-
Program/Sect
ion-205/
Long-term
program
Capital, Other
Cost sharing over
$100,000 or for
preparation of plans and
specifications and
construction. 65%
Federal/35% non-Federal
for cost of plan prep and
specifications and
construction.
The Feasibility Study is 100%
federally funded up to $100,000.
Projects must be economically
justified, environmentally sound, and
technically feasible. Not limited to
any particular type of improvement.
National
47
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Small Flood
Damage
Reduction
Projects (CAP
Section 205)
U.S. Army Corps
of Engineers
(USACE)
Public-
private
partner
ship
Federal
Provides funding for local protection from
flooding by the construction or improvement
of structural flood damage reduction
features such as levees, channels, and dams.
Non-structural alternatives are also
considered and may include measures such
as installation of flood warning systems,
raising and/or flood proofing of structures,
and relocation of flood prone facilities.
Additional information about this program:
http://www.lrl.usace.army.mil/Portals/64/do
cs/Outreach/lnformation/Section205.pdf
Requests for assistance should be in the
form of a letter describing the location and
nature of the problem and requesting
assistance under the program. The request
should be submitted by a state or local
government agency. State or local
government officials should consult the
nearest USACE District Engineer regarding
specific problems and the possibility of
remedial action under this program. Each
project must be economically justified,
environmentally sound, and technically
feasible.
http://www.u
sace.army.mil
/
Long-term
program
Capital, Other
Remainder of the study
phase is cost shared
50/50. Sponsor must
contribute 35% (min. 5%
cash) of total project
design and construction
cost as cash, in-kind
services or Lands,
Easements, Rights-of-way,
Relocation, and Disposal
areas.
Initial study is 100% federally
funded up to $100,000.
Conservation districts, local
governments, nonprofit
organizations, state/territorial
agencies, water and wastewater
utilities.
National
Solid Waste
Management
Grants
U.S.
Department of
Agriculture
(USDA) Rural
Utility Service
(RUS)
Grant
Federal
Reduces or eliminates pollution of water
resources by providing funding for
organizations that provide technical
assistance or training to improve the
planning and management of solid waste
sites. The Program statutes: Closed Dec 31,
2018.
Available online. Applications for this
program are accepted annually through the
local Rural Development (RD) office from
Oct. 1 to Dec. 31. Contact local RD office for
more information:
https://www.rd.usda.gov/contact-us/state-
offices
https://www.
rd.usda.gov/p
rograms-
services/solid
-waste-
management-
grants
Application
process,
Competitive
process,
Grant
program
Other,
Outreach
Competitive grants
Applicants: State and local
government entities, nonprofits,
federal recognized tribes, academic
institutions. Applicants must have
ability, background or experience to
successfully complete a similar
projects. Legal authority & tech
assistance, training.
National
Source
Reduction
Assistance
(SRA) Grant
Program
U.S.
Environmental
Protection
Agency (EPA)
Grant
Federal
Supports pollution prevention through
source reduction and resource conservation
work. As authorized under the statutory
authorities for this grant program, proposals
must carry out project activities using one or
more of the following methods "surveys,
studies, research, investigation,
experimentation, education, training and/or
demonstrations."
Applicants, must apply for SRA grant funding
electronically through Grants.gov based on
the Grants.gov instructions in the
announcement.
https://www.
epa.gOv/p2/g
rant-
programs-
pollution-
prevention#sr
a
Application
process,
Competitive
process,
Grant
program
Other,
Outreach
5% matching required.
$20,000. Some
EPA regions
may have
different
award
minimums.
Total individual grant awards may
potentially be in the range of
$20,000 - $260,000 issued over a
two-year funding period. However,
some EPA regions may have
different award caps.
Eligible: States, DC, territory of US,
local governments, schools,
nonprofits, community-based
grassroots, tribes.
National
Source Water
Protection
Grant Program
State of
Washington -
Department of
Health
Grant
State
Grants are available for projects that protect
public drinking water sources (Group A).
Projects can benefit drinking water quality,
quantity, or both.
To be eligible, must be either: A nonprofit
Group A water system or local government
proposing a regional project. The project
must be reasonably expected to provide
long-term benefits to drinking water quality
or quantity.
https://www.
doh.wa.gov/C
ommunityand
Environment/
DrinkingWate
r/SourceWate
r/SourceWate
rProtection
Application
process,
Grant
program
Capital, Other
Water quantity projects
may be restricted to 50%
of total annual funding
available.
Typically does not exceed $30,000,
but is dependent on the project.
Eligible projects include: Source
water protection studies: watershed,
hydrogeologic, feasibility studies.
Eligible activities lead to reducing the
risk of contamination and must
contribute to protecting one or more
public water supply sources.
WA
South Carolina
Clean Water
State
Revolving Fund
(CWSRF)
South Carolina
Rural
Infrastructure
Authority (RIA) -
Office of Local
Government
(OLG), South
Carolina
Department of
Health and
Environmental
Control (DHEC)
Loan
State
The program provides low-interest rate loans
for building or repair to wastewater plants or
distribution systems and stormwater quality
improvement projects. Eligible projects
include qualified water or energy reduction
component, low impact development or
other environmentally innovative "green"
practices. Must be on state's Comprehensive
Priority List.
Submit project questionnaire to DHEC;
Contact RIA OLG to determine what
preliminary financial information needs to be
submitted; Consult with DHEC for guidance
on preparing a Preliminary Engineering
Report (PER) and the plans and
specifications. Submit loan application to RIA
OLG about 30 days prior to sending plans &
specs to DHEC. Applications found online.
http://www.s
cdhec.gov/srf
/
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital
Low interest rate loans.
Loan repayments pay for
more loans.
$207,000,000 total has been
approved for FY19.
Municipalities, counties, and special
purpose districts can apply.
SC
48
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
South Carolina
Drinking Water
State
Revolving Fund
(DWSRF)
South Carolina
Department of
Health and
Environmental
Control (DHEC)
Loan
State
States can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Applicants must submit a DWSRF Project
Questionnaire to SC DHEC to be placed on
the State's Comprehensive Priority List.
Application information and documents
available at
https://www.scdhec.gov/environment/busin
esses-and-communities-go-
green/environmental-loans-grants-
businesses-communities-4.
https://www.
scdhec.gov/e
nvironment/b
usinesses-
and-
communities-
go-
green/enviro
nmental-
loans-grants-
businesses-
communities-
3
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
SC
South Carolina
Rural
Infrastructure
Authority
Grants
South Carolina
Rural
Infrastructure
Authority
Grant
State
The South Carolina Rural Infrastructure
Authority offers multiple options for
financing critical community infrastructure
improvements that will help maintain a safe
and healthy environment for residents,
support economic development and
contribute to a more sustainable future.
Rural Infrastructure Authority (RIA) Board of
directors reviews all qualified projects and
makes the funding decisions. Application
instructions: https://ria.sc.gov/grants/how-
to-apply/
http://www.ri
a.sc.gov/
Application
process,
Competitive
process,
Grant
program,
Long-term
program
Capital
Whenever possible, RIA
will leverage additional
resources to maximize
impact of the projects
statewide. Grantees must
cover non-construction
costs, and Tier 1 and II
counties must provide
25% of total project
construction cost.
The maximum grant award is
typically $500,000.
Local governments, special purpose
and public service districts, public
work commissions may apply.
SC
South Carolina
Rural
Infrastructure
Authority
Loans
South Carolina
Rural
Infrastructure
Authority
Loan
State
Offers multiple options for financing critical
community infrastructure improvements
that will help maintain a safe and healthy
environment for residents, support
economic development and contribute to a
more sustainable future.
Application instructions available at:
https://ria.sc.gov/grants/how-to-apply/
http://www.ri
a.sc.gov/
Application
process, Loan
program
Capital
Low interest loans.
Typically $500,000.
Loans are available to: municipalities,
counties, and special purpose
districts for a variety of clean water
and drinking water projects.
SC
South Dakota
Clean Water
State
Revolving Fund
(CWSRF)
South Dakota
Department of
Environment &
Natural
Resources
(DENR)
Loan
State
Provides low interest loans to governmental
entities for clean water and non-point source
pollution control projects.
Applications must be postmarked or
received on or before the first day of
January, April, July, and October. DENR will
present applications to the board after the
required technical review and financial
analysis have been completed. DENR will
notify applicants of the date forthe board
meeting at which applications will be
considered. Applications can be found
online.
https://denr.s
d.gov/dfta/w
wf/cwsrf/cws
rfprogram.as
px
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
The amount of funds available is
dependent upon the amount of
appropriations from the U.S.
Congress and the amount of
repayments from funds previously
loaned.
Must be a government entity with
the authority to generate revenue
and to repay. Project must be on the
State Water Plan prior to submitting
funding application. Must be a
Intended Use Plan. For: wastewater
projects and non-point source mgmt.
activities.
SD
South Dakota
Consolidated
Water
Facilities
Construction
Program
South Dakota
Department of
Environment &
Natural
Resources
(DENR)
Grant
State
Provides grants and loans for water-related
projects.
An applicant must submit an original
application to the DENR, which can be
accessed on the website. Applications must
be postmarked or received on or before the
first day of January, April, July, or October.
https://denr.s
d.gov/dfta/w
wf/consolidat
ed/consolidat
ed.aspx
Application
process,
Grant
program,
Long-term
program
Capital, O&M
The amount of funds available is
dependent upon the amount
appropriated by the Legislature
and the amount of funds
previously awarded. Interest rates
are available online.
Must be on the State Water Facilities
Plan, be sponsored by one of the
following: special purpose district,
state agency or general purpose
government, federally recognized
Indian Tribe, or nonprofit
corporation. Water related project.
SD
49
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
South Dakota
Consolidated
Water
Facilities
Construction
Program
South Dakota
Department of
Environment &
Natural
Resources
(DENR)
Loan
State
The Consolidated Water Facilities
Construction Program was established to
provide grants and loans for water-related
projects. To be eligible for this program, a
project must: be included on the State Water
Facilities Plan prior to the application
deadline; and be sponsored by one of the
following entities: a special purpose district
that has the authority to construct a water
resources project; a state agency or general
purpose government such as a municipality,
county, or township; a federally recognized
Indian tribe; or a nonprofit corporation.
An applicant must submit an original
application to the department, which can be
accessed on the website. Applications must
be postmarked or received on or before the
first day of January, April, July, or October.
https://denr.s
d.gov/dfta/w
wf/consolidat
ed/consolidat
ed.aspx
Application
process,
Grant
program,
Loan program
Capital
The amount of funds available is
dependent upon the amount
appropriated by the Legislature
and the amount of funds
previously awarded. Interest rates
are available online.
SD
South Dakota
Drinking Water
State
Revolving Fund
(SRF) Program
South Dakota
Department of
Environment
and Natural
Resources
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. SD uses a portion of its set-aside
to provide assistance to water systems to
acquire land or a conservation easement for
source water, protection, provide assistance
to a community water system to implement
voluntary, incentive-based source water
quality protection measures, and to provide
funding to delineate and assess source water
protection areas.
Application documents available at:
http://denr.sd.gov/dfta/wwf/dwsrf/E2126LD
V6-DWFundApp.pdf. Applications must
include must include the entity's most recent
audited financial statements or unaudited
annual reports. Applications must also
include a Drinking Water Facilities Plan must
be prepared and submitted as part of the
Drinking Water SRF application.
http://denr.s
d.gov/dfta/w
wf/dwsrf/dws
rfprogram.as
px
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
SD
Southeast
Rural
Community
Assistance
Project
(SERCAP)
Individual
Assistance
Water Well,
Septic Tank,
and Home
Improvement
Loan and
Grant Program
Southeast Rural
Community
Assistance
Project
(SERCAP)
Grant
State
Low interest loans and grants available to
construct, refurbish, or replace individual
water well systems, septic systems, or home
improvements. Eligible applicants live in
eligible rural areas in SERCAP's seven state
service area. Applicants must own and
occupy the home being repaired. New home
construction and community water systems
are not eligible. Household income may not
exceed the state median income limit.
Contact a SERCAP staff for further
information at (540)-345-1184.
Application is available at:
http://www.vdh.virginia.gov/content/upload
s/sites/20/2016/05/SERCAP-Universal-App.-
02.17p.pdfMail application to: Southeast
Rural Community Assistance Program
(SERCAP) 347 Campbell Avenue, SW
Roanoke, VA 24016
http://www.v
dh.Virginia.go
v/content/upl
oads/sites/20
/2016/05/SER
CAP-
Universal-
App.-
02.17p.pdf
Application
process,
Grant
program,
Loan program
Capital, Other
Individual Well Loan maximum is
$11,000; Septic Loan and Home
Improvement Program
(Households in VA and DE only):
Up to $9,000 for construction of
new septic tank, up to $6,000 for
repairs or upgrades to an existing
septic tank, up to $6,000 for
repairs or modifications to a home
that increases the health, or safety
standard of living; Miscellaneous
Grant Program (Households in VA
only): $600 towards
water/wastewater repair projects,
$1000 towards installation of a
new well, $1,000 towards a tap fee
for water/wastewater, $1,500
towards installation of new septic
system, $2,000 towards a new
alternative septic system, $3,500
maximum towards laterals for
water/wastewater.
Must live in an eligible location,
applicants must own and occupy the
home being improved, new home
construction and community water
systems are not eligible, household
income may not exceed the state
medium income.
VA, DE,
MD, NC,
SC, GA, FL
50
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Southeast
Rural
Community
Assistance
Project
(SERCAP)
Individual
Assistance
Water Well,
Septic Tank,
and Home
Improvement
Loan and
Grant Program
Southeast Rural
Community
Assistance
Project
Loan
State
Low-interest loans and grants available to
construct, refurbish, or replace individual
water well systems, septic systems, or home
improvements. Eligible applicants live in
eligible rural areas in SERCAP's seven state
service area. Applicants must own and
occupy the home being repaired. New home
construction and community water systems
are not eligible. Household income may not
exceed the state median income limit.
Contact a SERCAP staff for further
information at (540)-345-1184.
Application is available at:
http://www.vdh.virginia.gov/content/upload
s/sites/20/2016/05/SERCAP-Universal-App.-
02.17p.pd Mail application to: Southeast
Rural Community Assistance Program (SER)
347 Campbell Avenue, SW Roanoke, VA
24016
http://www.v
dh.Virginia.go
v/content/upl
oads/sites/20
/2016/05/SER
CAP-
Universal-
App.-
02.17p.pdf
Application
process, Loan
program
Other
Individual Well Loan: $11,000;
Septic Loan and Home
Improvement Program
(Households in VA and DE only):
$9,000 for construction of new
septic tank, up to $6,000 for
repair, up to $6,000 for repairs or
modifications to a home that
increases the health, or safety
standard of living; Miscellaneous
Grant Program (Households in VA
only): $600 towards
water/wastewater repair projects,
$,000 towards installation of a new
well, $1,000 towards a tap fee for
water/wastewater, $1,500 towards
installation of new septic system,
$2,000 towards a new alternative
septic system, $3,500 maximum
towards laterals for
water/wastewater.
Residence must be in an eligible rural
area, town, or community in SERCP
seven state area. Applicants must
own the home being improved, new
homes are not eligible, household
income must not exceed the state
median income limit.
VA, DE,
MD, NC,
SC, GA, FL
Southeast
Rural
Community
Loan Fund
Program
Southeast Rural
Community
Assistance
Project
(SERCAP)
Loan
Private
Offers low-interest loans to low-income,
rural communities, and businesses for
water/wastewater, housing, and community
development activities.
Applications are received year round.
Application forms can be accessed on
website.
http://www.s
ercap.org/
Application
process, Loan
program
Capital, O&M
None
Individual loans maximum is
$15,000. Community Development
loan maximum is $250,000.
Project must be in the SERCAP
(Southeastern US) Region. $30
application fee.
DE, MD,
VA, SC,
NC, GA,
FL
Special
Evaluation
Assistance for
Rural
Communities
and
Households
(SEARCH)
U.S.
Department of
Agriculture
(USDA) Rural
Utility Service
(RUS)
Grant
Federal
Helps very small, financially distressed rural
communities with predevelopment
feasibility studies, design and technical
assistance on proposed water and waste
disposal projects.
Contact your Rural Development (RD) Office
for more application information:
https://www.rd.usda.gov/contact-us/state-
offices. Apply online:
https://rdapply.usda.gov. Applications are
accepted through out the year.
https://www.
rd.usda.gov/p
rograms-
services/sear
ch-special-
evaluation-
assistance-
rural-
communities-
and-
households
Application
process,
Grant
program,
Long-term
program
Capital, Other
Eligible: Most states and local
governmental entities, nonprofits,
federally recognized tribes. Areas
served must be rural and financially
distressed. Populations of 2,500 or
80% less of metro area.
National
Sponsorship
Program
Chesapeake Bay
Trust
Grant
Private
Designed to support events that will increase
awareness within the targeted audience
about issues pertaining to restoration and
protection of the natural resources of the
Chesapeake and/or Maryland's other
watersheds. The Chesapeake Bay Trust will
entertain requests to sponsor events, such
as conferences, festivals, and forums that
allow the Trust to advance its mission. The
Trust will also entertain requests that
promote the two major sources of revenue
for the Trust, the Treasure the Chesapeakeffl
license plate program and the Chesapeake
and Endangered Species Tax Check-off on
the Maryland State income tax.
https://www.grantrequest.com/SID_1520PS
A=SNA&FID=35174; applications are
accepted on a rolling basis. Requests for the
Sponsorship Program are accepted on an
ongoing basis until funds are fully expended
for the fiscal year.
https://cbtrus
t.org/grants/s
ponsorship-
program/
Application
process,
Grant
program
Other,
Outreach
Matching encouraged but
not required.
None
$5,000, though to enable the Trust
to consider a wide range of
sponsorships throughout our fiscal
year, most sponsorships will be
limited to $1,000 for
programmatic support and $500
for marketing support.
Eligible entities include nonprofits,
community association, faith-based
organizations, etc. Sponsorship must
serve a Maryland audience but can
be anywhere within the Chesapeake
Bay watershed. For: conferences,
festivals, forums, events, etc.
DE, MD,
NY, PA,
VA, WV
51
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
State of Hawaii
Drinking Water
State
Revolving Fund
program
(DWSRF)
State of Hawaii
Department of
Health (DOH),
Environmental
Management
Division (EMD),
Safe Drinking
Water Branch
(SDWB)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents available at:
https://health.hawaii.gov/sdwb/drinking-
water-state-revolving-fund/. Applicants must
first submit a "Proposed Project for SRF
Funding" form and a Capacity evaluation
checklist. HI uses a portion of its set-aside to
create local SWP advisory committees,
develop SWP plans and strategies, conduct
source water assessments, and implement
protection activities including outreach and
educational programs.
https://health
.hawaii.gov/s
dwb/drinking-
water-state-
revolving-
fund/
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
HI
Storm Water
Grant Program
(SWGP)
California State
Water
Resources
Control Board
(SWRCB)
Grant
State
Funds storm water and dry weather runoff
projects that best advance the SWRCB's
policy goals of improving water quality and
realizing multiple benefits from the use of
storm water and dry weather runoff as a
resource.
Applicants are encouraged to have their
plans reviewed in advance of the solicitation.
Must submit SWRP or FE-SWRP, a completed
self-certification checklist, and a cover letter
explaining the approach used to arrive at a
functionally equivalent document (if
applicable) to swgp@waterboards.ca.gov to
obtain SWRCB concurrence review.
https://www.
waterboards.
ca.gov/water
Jssues/progr
ams/grantsj
oans/swgp/
Application
process,
Grant
program
Capital, Other
None
Varies
Public agencies, nonprofit
organization, public utilities, federally
recognized tribes, and mutual water
companies. Beneficial use of
stormwater and dry weather runoff.
Improve water quality.
CA
Sustainable
Agriculture
Research and
Education
(SARE)
U.S.
Department of
Agriculture
(USDA)
Grant
Federal
The Sustainable Agriculture Research and
Education (SARE) program of the U.S.
Department of Agriculture (USDA) National
Institute of Food and Agriculture (NIFA)
works to advance farming systems that are
productive, profitable, environmentally
sound and good for communities through a
regional grants program.
SARE's four regions offer an array of
competitive grants for researchers,
agricultural educators, students, farmers and
ranchers in the United States. Visit
http://www.sare.org/Grants/Apply-for-a-
Grant to identify your SARE region and view
grant opportunities.
http://www.s
are.org/
Application
process,
Competitive
process,
Grant
program,
Long-term
program
Other
Grants are regionally
administered with
different requirements for
each.
Varies based on region and grant
type.
For: researchers, agricultural
educators, students, farmers and
ranchers. Grants are for innovative
research and education projects.
National
Tennessee
Clean Water
State
Revolving Fund
Loan (CWSRF)
Tennessee
Department of
Environment
and
Conservation
(DEC)
Loan
State
Provides loans for the Planning, Design, and
Construction Phases of wastewater facility
projects. The funds may be used for all three
phases in any combination. Eligible projects
include new construction or the
upgrading/expansion of existing facilities and
may encompass wastewater treatment
plants, pump stations, force mains, collector
sewers, interceptors, elimination of
combined sewer overflows, and/or non-
point source pollution remedies.
Submit a Letter of Request and complete a
questionnaire to have project reviewed for
placement. Projects must be on PRLto be
eligible to receive financial assistance.
Applications can be found online. Contact
state office for more information.
https://www.
tn.gov/enviro
nment/progr
am-areas/wr-
water-
resources/wa
ter-
quality/state-
revolving-
fund-
program/stat
e-revolving-
fund/wr-srf-
clean-water-
state-
revolving-
fund-loan-
program.html
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Principal repayments and
interest payments sustain
the revolving fund.
Varies
TN
52
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Tennessee
Drinking Water
State
Revolving Fund
(DWSRF)
Tennessee
Department of
Environment
and
Conservation
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Applicants must submit a Letter of Request
and Questionnaire to be placed onto the
Priority Ranking List (PRL). Application
documents available at:
https://www.tn.gov/environment/program-
areas/wr-water-resources/srfp/srf-home/i-
need-funding.html.
https://www.
tn.gov/enviro
nment/progr
am-areas/wr-
water-
resources/srf
p/srf-
home/drinkin
g-water-
state-
revolving-
fund.html
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose how to
use the 15% set-aside
annually. Funds can be
used to coordinate with
other programs. Green
projects may have
subsidies. State
encourages protection of
source water using green
infrastructure, and correct
water loss issues.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
TN
Texas Clean
Water State
Revolving Fund
(CWSRF)
Texas Water
Development
Board
Loan
State
Provides low-cost financial assistance for
planning, acquisition, design, and
construction of wastewater, reuse, and
stormwater infrastructure.
CWSRF financing is available year round. In
order to be invited to apply for funding,
entities must submit a completed Project
Information Form. Apply online.
http://www.t
wdb.texas.go
v/financial/pr
ograms/CWS
RF/
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Entities receiving
assistance greater than
$500,000 must adopt a
water conservation and
drought contingency plan.
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan. Total
funds available is approximately
$525,000,000
Must be a political subdivision, Indian
tribal organization, private entities
for non-point source or estuary
projects.
TX
Texas Drinking
Water State
Revolving Fund
(DWSRF)
Texas Water
Development
Board (TWDB)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. TX DWSRF uses a portion of its
set-aside to implement Source Water
Protection Program activities, including: (1)
evaluations of sources (surface and
wellhead) to determine vulnerability to
contamination, (2) implementation of SWP
programs, (3) BMP development, and more.
Application documents available at:
https://ola.twdb.texas.gov/. Applicants must
first submit a Project Information Form to
the current TX Intended Use Plan and attend
a pre-application meeting before submitting
a financial assistance application.
http://www.t
wdb.texas.go
v/financial/pr
ograms/DWS
RF/index.asp?
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
TX
Texas Water
Development
Fund(DFund)
Texas Water
Development
Board
Loan
State
State-funded loan program that does not
receive federal subsidies and is not subject
to federal crosscutters. The DFund enables
the Board to fund multiple eligible
components in one loan to borrowers, e.g.,
an application for funding of water and
wastewater components can be processed in
a single loan. Eligible projects: water supply
and wastewater projects for planning,
design, and construction. Financial
assistance for flood control.
Online Loan Application System:
https://ola.twdb.texas.gov; Download Paper
Application:
http://www.twdb.texas.gov/financial/applica
tions/index.asp
http://www.t
wdb.texas.go
v/financial/pr
ograms/TWD
F/index.asp
Application
process, Loan
program,
Long-term
program
Capital
Entities receiving
assistance greater than
$500,000 must adopt
water conservation and
drought contingency
plans.
$6 billion evergreen bonding
authority.
Eligible: political subdivisions of the
state and nonprofit water
corporations.
TX
53
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
The
Environmental
Justice
Collaborative
Problem-
Solving (CPS)
Cooperative
Agreement
Program
U.S.
Environmental
Protection
Agency (EPA)
Grant
Federal
Provides financial assistance to eligible
organizations working on or planning to
work on projects to address local
environmental and/or public health issues in
their communities, using EPA's
"Environmental Justice Collaborative
Problem-Solving Model."
Request for an application online. Applicants
must be located within the state, territory,
commonwealth, or tribe where the project is
located.
https://www.
epa.gov/envir
onmental-
justice/enviro
nmental-
justice-
collaborative-
problem-
solving-
cooperative-
agreement-0
Application
process,
Competitive
process,
Grant
program
Other,
Outreach
Funding of $120,000 per award.
Two year-project period. Ten
awards.
Must be a local community-based
organization, tribe, or tribal
organization.
National
The George
Gund
Foundation:
Economic
Development
and
Community
Revitalization
Grant
The George
Gund
Foundation
Grant
Private
Sustaining uniquely urban assets such as
vibrant neighborhoods and a thriving
downtown is a key part of a successful
regional strategy to promote economic
growth. The Foundation devotes
considerable attention to these dynamics, in
particular by supporting collaborative efforts
that leverage resources. As a result, the
highest priority is given to initiatives that
bolster the impact of Foundation-supported
intermediary organizations working to
improve the competitiveness of Cleveland's
neighborhoods and its metropolitan region.
Examples of such initiatives include quality
urban planning and design, improvements to
urban parks and public spaces, promotion of
equal opportunity and diversity in housing
and the workplace and proposals to
redevelop Cleveland's downtown,
neighborhoods and first-ring suburbs.
Applications are submitted online and
considered three times a year by the
Foundation's Trustees. Applications are due
March 15 (for summer meeting), July 15 (for
fall meeting), and November 15 (for winter-
spring meeting). Applicants must provide a
list of other funding received or funding they
are seeking. More information can be found
at: https://gundfoundation.org/how-to-
apply/proposal-deadlines/.
https://gundf
oundation.or
g/
Application
process,
Grant
program,
Long-term
program
Capital, Other
Collaborative efforts as
leverage. Rarely funds
100% of a project.
The Foundation's Board of
Trustees have made 236 grants
(for all program areas) totaling
$22,445,348 in 2017.
Must be a federally tax-exempt
charitable organization on file with
the IRS, a government unit or agency,
a local education agency or library.
OH
The George
Gund
Foundation:
Environment
Grant
The George
Gund
Foundation
Grant
Private
Makes grants to organizations that address
environmental issues in Northeast Ohio.
Supports efforts to restore and preserve the
Lake Erie ecosystem. Within the broad range
of environmental issues, the Foundation
focuses on promoting alternatives to urban
sprawl, decreasing energy consumption and
waste, conserving ecosystems and
biodiversity, reducing environmental health
hazards, increasing public awareness of
environmental issues and building the skills
of nonprofit environmental leaders.
Applications are submitted online and
considered three times a year by the
Foundation's Trustees. Applications are due
March 15 (for summer meeting), July 15 (for
fall meeting), and November 15 (for winter-
spring meeting). Applicants must provide a
list of other funding received or funding they
are seeking. More information can be found
at: http://gundfoundation.org/what-we-
fund/program-guidelines/.
https://gundf
oundation.or
g/
Application
process,
Grant
program,
Long-term
program
Other,
Outreach
Collaborative efforts as
leverage. Rarely funds
100% of a project.
The Foundation's Board of
Trustees have made 236 grants
(for all program areas) totaling
$22,445,348 in 2017.
Eligible Applicants: federally tax-
exempt charitable organization on
file with the IRS, a governmental unit
or agency, a local education agency
or a library. Must be in Northeastern
Ohio or benefit Lake Erie.
OH
The McKnight
Foundation:
Midwest
Climate &
Energy Grant
The McKnight
Foundation
Grant
Private
Engages the region's public and private
leaders, decision makers, and citizens in
building low-carbon communities and
economies that are vibrant, equitable, and
resilient. The Foundation achieves these
goals through grants, investments,
convening and community engagement.
Uses a closed application process; proposals
for funding are accepted only from
organizations that are invited by McKnight
Foundation staff to apply.
https://www.
mcknight.org/
grant-
programs/mi
dwest-
climate-and-
energy
Application
process,
Grant
program
Other,
Outreach
The program leverages its
limited philanthropic
funding by supporting
efforts that address
systemic and structural
barriers to a clean energy
transition.
In 2017, The McKnight Foundation
awarded 70 grants totaling $15
million.
Must be a tax-exempt, nonprofit.
Organizations must be invited to
apply.
MN
54
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
The McKnight
Foundation:
Region and
Communities
Grant (R&C)
The McKnight
Foundation
Grant
Private
The goal of the McKnight Foundation's
Region and Communities (R&C) grant
program is to increase efficient and
sustainable regional metropolitan
development that creates livable
communities and expands opportunities.
Program strategies include sustainable
regional development, affordable housing,
and economically vibrant neighborhoods.
Primary geographic focus is the Twin Cities
metropolitan region.
Applications for the Region and Communities
(R&C) grant program are submitted online
on a quarterly basis. The online application
system opens approximately two weeks
prior to each initial inquiry deadline. The
inquiry submission date will determine when
a full proposal, if invited, is considered by the
board. Deadlines are: October 15 for
February consideration; January 15 for May
consideration; April 15 for August
consideration; and July 15 for November
consideration. Application instructions are
available at:
https://www.mcknight.org/grant-
programs/region-and-communities.
https://www.
mcknight.org/
grant-
programs/reg
ion-and-
communities
Application
process,
Grant
program,
Long-term
program
Other,
Outreach
Leverage for public,
philanthropic, and private
resources.
In 2017, issued 124 grants totaling
$21 million.
Must be tax except nonprofit. For
planning, operating, and project
grants. Consider capital grants only in
exceptional circumstances.
MN
The
Rockefeller
Foundation:
Grant
The Rockefeller
Foundation
Grant
Private
The Rockefeller Foundation works to achieve
meaningful and measurable impact for poor
and vulnerable communities through smart
globalization. A portfolio of work structured
around core issue areas include: health,
food, power, jobs, resilient cities, innovation
and co-impact.
During 2018, The Rockefeller Foundation is
reviewing and assessing their areas of focus
and grant-making to ensure that they are
most effectively delivering on our mission to
promote the well-being of humanity
throughout the world. Therefore, the
Foundation is not accepting or reviewing
unsolicited proposals at this time (unless
requested to do so by a Foundation staff
member). Unsolicited proposals are not
being accepted at this time.
https://www.
rockefellerfou
ndation.org/
Grant
program,
Long-term
program
Other,
Outreach
$10,000
$3 million
Not accepting or reviewing
unsolicited proposals at this time.
Projects must fall within one of the
Current Initiatives. Must address
more than one of the funding areas.
NY
Title XVI Water
Reclamation &
Reuse Program
US Department
of the Interior
(DOI) - Bureau
of Reclamation
Grant
Federal
The Bureau of Reclamation identifies and
investigates opportunities to reclaim and
reuse wastewaters and naturally impaired
ground and surface water in the 17 Western
States and Hawaii. Title XVI includes funding
for feasibility studies and research, and the
construction of water recycling projects on a
project specific basis, in partnership with
local governmental entities.
Three Funding Opportunity Announcements
(FOAs) are offered under the Title XVI
Program: (1) planning, design, and
construction of Congressionally Authorized
Title XVI Projects; (2) Feasibility Studies; and
(3) Research. FOAs are expected to be
posted in October and November. To receive
email updates, send a blank email to
watersmart@usbr.gov with Title XVI in the
subject line.
http://www.u
sbr.gov/Wate
rSMART/title/
index.html
Application
process, Fund
allocation to
states and
localities,
Grant
program
Capital
Coast sharing/matching is
required.
In 2017, six projects received a
total of $20,980,129 for planning,
design and/or construction
activities; 13 projects received a
total of $1,791,561 to develop new
water reclamation and reuse
feasibility studies; and four
projects received a total of
$847,701 for research to establish
or expand water reuse markets,
improve or expand existing water
reuse facilities, and streamline the
implementation of clean water
technology at new facilities.
Must be an eligible organization.
Project must be water reclamation
and reuse authorized for funding
under Title CVI Act. Cannot go to
federal entities, research institutions,
nonprofits, and individuals.
National
Treasure State
Endowment
Program
(TSEP)
Montana
Department of
Commerce -
Community
Development
Division
Grant
State
State-funded program designed to help
address the affordability of local
infrastructure projects by lowering the cost
of constructing public facilities. Grant
categories include Planning, Projects, and
Emergency.
Application and guidelines can be found
online.
http://comde
v.mt.gov/pro
grams/TSEP
Application
process,
Grant
program,
Long-term
program
Capital,
Compliance,
O&M, Other
State funded grant
program.
Maximum grant values depend on
the grant type. Projects average
$600,000.
Eligible applicants include cities,
towns, counties, special purpose
districts, and tribal
governments.
MT
Tribal
Environmental
Regulatory
Enhancement
Program
U.S.
Department of
Health &
Human Services
(DHHS)
Grant
Federal
Grants provide tribes with resources to
develop legal, technical and organizational
capacities for protecting their natural
environments. Grants build tribal capacity,
allowing involvement in all aspects of each
project, including: Environmental issue
identification, Planning, Development, and
Implementation.
Visit
https://ami.grantsolutions.gov/index.cfmPsw
itch=searchresult&type=office¶m=ANA
&page=ANA to view and apply for current
funding opportunities.
https://www.
acf.hhs.gov/a
na/programs/
environmenta
l-regulatory-
enhancement
Application
process,
Competitive
process,
Grant
program
Other
Leveraged Resources: The
total dollar value of all
non-ANA resources that
are committed to a
proposed ANA project and
are supported by
documentation that
exceed the 20% non-
federal match required
for an ANA grant.
Estimated $1.75 million total in
FY2016.
Applicants must describe a land base
or other resource over which they
exercise jurisdiction as part of their
application.
National
55
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Urban and
Community
Forestry
Program
U.S. Forest
Service
Grant
Federal
Cooperative program of the U.S. Forest
Service that focuses on the stewardship of
urban natural resources, providing grants for
urban forestry projects.
https://www.
fs.fed.us/man
aging-
land/urban-
forests/ucf
Fund
allocation to
states and
localities,
Grant
program
Capital,
Other,
Outreach
Funds can be used to
leverage and diversify
funding, expand
collaboration between
urban forestry and related
fields, agencies, and
sectors.
ri ujects must align with the seven
goals in the Ten-Year Urban Forestry
Action Plan (2016-2026).
National
Urban Waters
Small Grants
(UWSG)
U.S.
Environmental
Protection
Agency (EPA)
Grant
Federal
The objective of the Urban Waters Small
Grants (UWSG) is to fund projects that will
foster a comprehensive understanding of
local urban water issues, identify and
address these issues at the local level, and
educate and empower the community. In
particular, the UWSG seek to help restore
and protect urban water quality and
revitalize adjacent neighborhoods by
engaging communities in activities that
increase their connection to, understanding
of, and stewardship of local urban
waterways.
Grants are awarded every other year.
Currently no open RFPs.
https://www.
epa.gov/urba
nwaters/urba
n-waters-
small-grants
Application
process,
Grant
program
Other,
Outreach
Currently no open RFPs;
Promotes successful
collaborative
partnerships.
$60,000
Grants are awarded every two years.
Should meet four program
objectives. Eligible: States, local
governments, tribes,
universities/colleges, nonprofits,
intertribal consortia, interstate
agencies.
National
Utah Clean
Water State
Revolving Fund
(CWSRF)
Utah
Department of
Environmental
Quality
Loan
State
The CWSRF funds water quality and
wastewater infrastructure projects in Utah
including green infrastructure, water and
energy efficiency, and environmentally
innovative projects.
Projects must apply to be on the annual
priority list. Applications can be found online.
Contact Utah Division of Water Quality for
more information.
https://deq.u
tah.gov/wate
r-
quality/financ
ial-assistance-
programs-
water-quality
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan repayments are used
to fund additional water
quality projects.
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
Must be on the annual priority list.
Municipalities are eligible to receive
loans for wastewater treatment or
collection system infrastructure.
UT
Utah Drinking
Water State
Revolving Fund
(DWSRF)
Utah
Department of
Environmental
Quality
Loan
State
Provides finance assistance to eligible public
water systems for infrastructure projects,
administration, technical assistance, and
source water protection aimed at improving
drinking water quality.
To initiate the process, complete and submit
the combined application form. Application
is evaluated by Division of Drinking Water
(DDW) staff, assigned priority points, and
placed on a Project Priority List.
https://deq.u
tah.gov/drinki
ng-
water/federal
-state-
revolving-
fund-srf-
program-
drinking-
water
Application
process, Loan
program,
Long-term
program
Capital,
Compliance,
Other
Low interest loans.
Funding level determined by
priority, number of applicants, and
total DWSRF amount to loan.
For publicly- and privately-owned
and nonprofit non-community water
systems.
UT
Utah State
Revolving Fund
(SRF): Drinking
Water
Utah
Department of
Environmental
Quality (DEQ)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents are available at:
https://deq.utah.gov/drinking-water/state-
revolving-fund-srf-drinking-water. Applicants
must submit the most recent audit or
financial statement of the applicant along
with their loan application. Further, an
engineering report needs to accompany the
application. The report must: describe the
need for a project; list the various project
alternatives which were examined; and
justify the selection of the project which is
being proposed.
https://deq.u
tah.gov/drinki
ng-
water/state-
revolving-
fund-srf-
drinking-
water
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
UT
56
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Vermont Clean
Water State
Revolving Loan
Fund (CWSRF)
Vermont
Department of
Environmental
Conservation
(DEC)
Loan
State
Provides loans to municipalities or
municipally-sponsored privately-owned
systems for facilities planning, final design,
and construction.
Projects must apply to be on the annual
priority list by submitting an Intended Use
Plan. To be compliant with NEPA,
environmental reviews are required as well.
Applications and forms can be accessed on
website.
http://dec.ver
mont.gov/faci
lities-
engineering/
water-
financing/cws
rf
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan repayments are used
to fund additional water
quality projects.
Funding terms vary based on loan
type. Planning Loans: Term of 5 to
15 years with 0% interest. Final
Design Loans: Terms of 5 to 15
years with 0% interest.
Construction Loans: Terms of 20 to
30 years with 2% administrative
fee, annually. Terms need to be
less than or equal to asset life.
Eligible projects: Wastewater and
stormwater; full list of examples on
webpage.
VT
Vermont
Community
Development
Program
(VCDP)
Vermont
Agency of
Commerce &
Community
Development
Grant
State
Assists communities on a competitive basis
by providing financial and technical
assistance to identify and address local need.
VCDP funds must primarily benefit persons
of low and moderate income. In addition,
assistance is provided to communities for
threats of health and safety issues as urgent
needs and slums and blight projects.
Applications can be completed online at:
https://grants.accd.vermont.gov/
http://accd.v
ermont.gov/c
ommunity-
development
/funding-
incentives/vc
dp
Application
process,
Grant
program,
Long-term
program
Capital, Other
Accessibility Modification Grants:
$5,000 to $75,000.
Implementation grants: $50,000 to
$1,000,000. Planning Grants:
$3,000 to $60,000. Scattered Site
Grants: $50,000 to $1,000,000.
Must be a VT town, city (except
Burlington), incorporated village
chartered to function as a general
purpose unit of local government or
a consortium of such entities. Can be
coordinated efforts between
municipalities, community groups,
and nonprofits.
VT
Vermont
Drinking Water
State
Revolving Fund
(DWSRF)
Vermont
Agency of
Natural
Resources,
Department of
Environmental
Conservation
Loan
State
States can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. State Source Protection Loans
require the water system to demonstrate
how the project will directly promote public
health protection or compliance with
national drinking water regulations.
Funding applications and instructions on
how to apply are available at:
https://dec.vermont.gov/water-
investment/water-financing/srf/how-to-
apply. Applications require several
attachments including a Engineering Services
Agreement, draft Level of Effort, any
subcontractors' proposals, small equipment
purchases, or other reimbursable costs.
https://dec.v
ermont.gov/
water-
investment/w
ater-
financing/dws
rf
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can be used to coordinate
with other programs, e.g.,
plans to meet CWSRF and
Section 319 grant
application requirements.
Also offer Planning,
Source Protection, and
Const. Loans.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
VT
Vermont
Municipal
Planning
Grants
Vermont
Agency of
Commerce &
Community
Development
Grant
State
Funding available for a variety of municipal
planning and revitalization projects,
including those that improve flood
protection, protect natural resources, and
promote efficient growth and development.
The Program Description, including
competitive criteria for the upcoming grant
round will be issued annually in early June.
Applications are due first of October. They
can be completed online here:
https://grants.accd.vermont.gov/.
http://accd.v
ermont.gov/c
ommunity-
development
/funding-
incentives/m
unicipal-
planning-
grant
Application
process,
Competitive
process,
Grant
program,
Long-term
program
Capital, Other
10% cash match required.
Projects with match
amounts greater than
10% receive additional
points in the competitive
criteria.
$22,000 for individual
municipalities and $35,000 for
consortia.
Eligible: Municipalities with
confirmed local planning process or
municipalities without a local
planning processes may apply for
funding to develop a municipal plan.
Must be located in VT. Projects must
be completed in 18 months.
VT
Virginia Clean
Water State
Revolving Fund
(CWSRF)
Virginia
Resources
Authority (VRA)
Loan
State
Funding is available for improvements to
publicly-owned wastewater collection and
treatment facilities; installation of publicly-
owned stormwater best management
practices; projects for the remediation of
contaminated brownfield properties; land
conservation projects and living shoreline
projects.
There is an annual solicitation and ranking of
applications. Funding is usually issued by a
Request for Proposal (RFP) June 1 with
applications due mid July. Applications can
be accessed on website.
https://www.
virginiaresour
ces.gov/page/
clean-water-
revolving-
loan-fund/
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Low interest rate loans
that provide funding for
future projects as they are
repaid. Virginia Resources
Authority (VRA) serves as
the financial manager of
the fund.
Approximately $100 million in total
funds available, annually.
Local governments eligible.
VA
57
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Virginia
Drinking Water
State
Revolving Fund
(DWSRF)
Virginia
Department of
Health
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents available at:
http://www.vdh.virginia.gov/drinking-
water/financial-construction-assistance-
programs/drinking-water-funding-program-
details/.
https://www.
virginiaresour
ces.gov/page/
drinking-
water-
revolving-
loan-fund/
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
VA
Virginia
Stormwater
Local
Assistance
Fund (SLAF)
Virginia
Department of
Environmental
Quality (DEQ)
Grant
State
Supports Non-Point Source Nutrient Credit
purchases and stormwater projects
including: i) new stormwater best
management practices; ii) stormwater best
management practice retrofits, iii) stream
restoration; iv) low impact development
projects, v) buffer restorations, vi) pond
retrofits, and vii) wetlands restoration.
To be considered for this funding, three
completed applications and one
Commonwealth of Virginia substitute W-9
form must be submitted. These forms can be
found online. Applications are due in
October.
https://www.
deq.virginia.g
ov/Programs/
Water/Clean
WaterFinanci
ngAssistance/
StormwaterL
ocalAssistanc
eFund(SLAF).
aspx
Application
process,
Grant
program,
Long-term
program
Capital, Other
Provides 50% of project
costs.
Approximately $20,000,000 is
available.
Projects that reduce non-point
source pollution from stormwater. To
be eligible must be a local
government agency in Virginia.
VA
Washington
Clean Water
State
Revolving Fund
(CWSRF) Loans
State of
Washington
Department of
Ecology (DOE)
Loan
State
Provides low interest and forgivable principal
loan funding for wastewater treatment
construction projects, eligible non-point
source pollution control projects, and eligible
green projects.
Apply via the current Combined Funding
Cycle process. Apply here:
https://ecology.wa.gov/About-us/How-we-
operate/Grants-loans/Find-a-grant-or-
loan/Water-Quality-Combined-Funding-
Program/WQC-funding-cycle. Guidelines can
be found here:
https://fortress.wa.gov/ecy/publications/Su
mmary Pages/1810030
Hardship Assistance: Jurisdictions listed with
a population of 25,000 less.
https://ecolo
gy.wa.gov/Ab
out-us/How-
we-
operate/Gran
ts-loans/Find-
a-grant-or-
loan/Water-
Quality-
grants-and-
loans
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Issues loans for terms of
5, 20, or 30 years with the
limitation that the term
cannot be longer than the
useful life of the project
being financed.
Varies
Stormwater grant: maximum
award per jurisdiction: $5 million,
with a required 25% match.
For wastewater treatment
construction projects, eligible non-
point source pollution control project
and eligible green projects. Pre-
construction set-aside (Distressed
Communities) 50% forgivable
principal loan and 50% loan.
WA
Washington
Community
Economic
Revitalization
Board (CERB)
Washington
State
Department of
Commerce
Grant
State
The Community Economic Revitalization
Board (CERB) provides funding to local
governments and Federally-recognized tribes
for public infrastructure which supports
private business growth and expansion.
Eligible projects include domestic and
industrial water, stormwater, wastewater,
public buildings, telecommunications, and
port facilities.
Contact staff when ready to apply for CERB
funding, and obtain a linkto the application.
To help with the application process, and
learn more about different funding
programs, review the information on our
Applicant/Client Resources page
(https://www.commerce.wa.gov/building-
infrastructure/community-economic-
revitalization-board/cerb-application-page/).
Board meets six times a year.
http://www.c
ommerce.wa.
gov/building-
infrastructure
/community-
economic-
revitalization-
board/
Application
process,
Grant
program
Capital, Other
Projects encourage
private and local
investments.
CERB has invested $163 million in
communities across the state.
Up to $50,000 per application.
Requires 25% match for Project
Specific Planning.
Construction Program: 20% match
for private and 50% match for
prospective partners.
Funds are awarded to local
governments for pubic infrastructure
projects.
WA
58
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Washington
Drinking Water
State
Revolving Fund
(DWSRF)
Washington
State
Department of
Health
Loan
State
States can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. The 2019 Intended Use Plan (IUP)
indicated that 5% of the Local Assistance and
Other State Programs set-asides will be used
to work with system to improve source
water protection and implement important
wellhead and watershed protection projects.
To achieve this the State will continue to
improve the program by engaging other
State and federal agencies, local
governments, and nongovernmental
organizations for collaboration.
Funding applications and forms are available
at:
https://www.d0h.wa.g0v/P0rtals/l/D0cume
nts/4200/19WALTAppWorksheet(l).pdf. The
State recommends that the applicant read
and understand the DWSRF Construction
Guidelines prior to completing the
worksheet. Worksheets must be mailed to
the State and postmarked by the set date for
that year.
https://www.
doh.wa.gov/c
ommunityand
environment/
drinkingwater
/watersystem
assistance/dri
nkingwaterSt
aterevolvingf
unddwsrf
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
$3 million per jurisdiction.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
WA
Water &
Environmental
Programs
(WEP)
U.S.
Department of
Agriculture
(USDA)- Rural
Development
(RD)
Grant
Federal
WEP is exclusively focused on the water and
waste infrastructure needs of rural
communities with populations of 10,000 or
less. The programs provide technical
assistance and financing for development of
drinking water, waste disposal, and
stormwater systems in rural areas.
Applications must be submitted via RDApply.
https://www.
rd.usda.gov/p
rograms-
services/all-
programs/wa
ter-
environmenta
l-programs
Application
process,
Competitive
process, One-
time
allocation
Capital,
Other,
Outreach
Eligible projects include construction
of water and waste facilities in rural
communities. Funds can also be used
for technical assistance and training
in rural communities in relation to
water and waste activities.
National
Water &
Waste Disposal
Grants to
Alleviate
Health Risks on
Tribal Lands
and Colonias
U.S.
Department of
Agriculture
(USDA) - Rural
Development
(RD)
Grant
Federal
Provides access to safe reliable drinking
water and waste disposal facilities and
services to low-income communities that
face significant health risks.
Applications for this program are accepted
through the local RD office year round.
https://www.
rd.usda.gov/p
rograms-
services/wate
r-waste-
disposal-
grants-
alleviate-
health-risks-
tribal-lands-
and-colonias
Application
process,
Grant
program,
Long-term
program
Capital
Matching is not required
but encouraged if other
partnerships exist.
Partnerships with other
federal, state and local
entities are encouraged.
Congressional appropriation varies
annually.
Eligible: State and local governmental
entities, nonprofit organizations,
utility district serving colonias,
federally recognized tribes. Areas
eligible: Tribal lands, Colonias
recognized prior to Oct 1, 1989, rural
areas and towns with pop less than
10 K.
National
Water &
Waste Disposal
Loan & Grant
Program
U.S.
Department of
Agriculture
(USDA) Rural
Utility Service
(RUS)
Loan
Federal
Provides funding for clean and reliable
drinking water systems, sanitary sewage
disposal, sanitary solid waste disposal, and
stormwater drainage to households and
businesses in eligible rural areas.
Apply online using Rural Development (RD)
apply: https://www.rd.usda.gov/programs-
services/water-waste-disposal-loan-grant-
programApplications are also accepted
through your local RD office:
https://www.rd.usda.gov/contact-us/state-
offices
https://www.
rd.usda.gov/p
rograms-
services/wate
r-waste-
disposal-loan-
grant-
program
Application
process,
Grant
program,
Loan program
Capital
Long-term, low-interest
loans, if funds are
available, grant may be
combined with a loan if
necessary.
$30,000 in WA
Must be a state or local government
entities, private nonprofit, federally
recognized tribes in a rural area or
town with pop. less than 10K tribal
lands, Colonias.
National
Water &
Waste Disposal
Loan & Grant
Program in
Pennsylvania
U.S.
Department of
Agriculture
(USDA) Rural
Development
(RD)
Loan
Federal
Provides funding for water, wastewater, and
stormwater systems in rural areas and towns
with a population not in excess of 10,000.
Funds are available to public bodies,
nonprofit corporations, and Indian tribes
Applications are accepted on a rolling basis.
Paper applications are accepted or
applicants can register for and use RD APPLY
https://www.
rd.usda.gov/p
rograms-
services/wate
r-waste-
disposal-loan-
grant-
program/pa
Application
process, Loan
program
Capital
Up to 40 year loan with
fixed interest rate.
Appropriations each fiscal year.
Eligible: State and local government
entities, private nonprofits, and
Federally-recognized tribes in a rural
area with populations 10K or less
with. Funding must be used for
acquisition, construction, or
improvement of the items listed on
the website.
PA
59
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Water &
Waste Disposal
Loan
Guarantees
U.S.
Department of
Agriculture
(USDA) Rural
Utility Service
(RUS)
Loan
Federal
Helps private lenders provide affordable
financing to qualified borrowers to improve
access to clean, reliable water and waste
disposal systems for households and
businesses in rural areas.
Lenders: Contact a representative in local
Rural Development (RD) office for details on
how to become an approved lender.
Borrowers: ask private lender if it
participates in USDA loan guarantee
programs. Questions should be directed to
local RD office:
https://www.rd.usda.gov/contact-us/state-
offices
https://www.
rd.usda.gov/p
rograms-
services/wate
r-waste-
disposal-loan-
guarantees
Application
process, Loan
program,
Long-term
program
Capital
Loan guarantees are
serviced through private
lenders.
The maximum guarantee is
typically 90% of the loan amount.
Interest rates may be fixed or
variable as negotiated between
the lender and the borrower,
subject to USDA approval. Up to
40-year payback period, based on
the useful life of the facilities
financed. Balloon payments are
prohibited.
Eligible: Most state and local
governmental entitles, nonprofit
organizations, and federally-
recognized tribes in rural areas and
towns with populations 10K or less.
National
Water &
Waste Disposal
Predevelopme
nt Planning
Grants
U.S.
Department of
Agriculture
(USDA) Rural
Utility Service
(RUS)
Grant
Federal
Assists low-income communities with initial
planning and development of applications
for USDA Rural Development Water and
Waste Disposal direct loan/grant and loan
guarantee programs.
Contact your Rural Development (RD) Office
for more application information:
https://www.rd.usda.gov/contact-us/state-
offices. Apply online:
https://rdapply.usda.govApplications are
accepted throughout the year.
https://www.
rd.usda.gov/p
rograms-
services/wate
r-waste-
disposal-
predevelopm
ent-planning-
grants
Application
process,
Grant
program,
Long-term
program
Other
At least 25% percent of
cost must come from the
applicant or third-party
source. In-kind
contributions do not
count toward this
minimum.
$30,000 or 75% of
predevelopment planning costs.
Grants to pay part of the cost of
developing a complete application
for USDA Rural Development Water
& Waste Disposal direct loan/grant
and loan guarantee programs.
Eligible: Most state and local
government entities, nonprofits,
Tribes.
National
Water &
Waste Disposal
Technical
Assistance &
Training
Grants
U.S.
Department of
Agriculture
(USDA) Rural
Utility Service
(RUS)
Grant
Federal
Helps qualified, private nonprofits provide
technical assistance and training to identify
and evaluate solutions to water and waste
problems; helps applicants prepare
applications for water and waste disposal
loans/grants; and helps associations improve
the operation and maintenance of water and
waste facilities in eligible rural areas.
Single-state applications are accepted
annually through local Rural Development
(RD) office from October 1 - December 31.
Multi-state or national applications are
accepted through the RD national office.
Program resources are available online
(forms, guidance, certifications, etc.).Guide:
https://www.rd.usda.gov/files/ApplicationGu
ideTAT_SWMGrantsFY2018-FINAL.pdf.
Contact local RD office:
https://rdapply.usda.gov. Closed at the end
of 2018.
https://www.
rd.usda.gov/p
rograms-
services/wate
r-waste-
disposal-
technical-
assistance-
training-
grants
Application
process,
Grant
program,
One-time
allocation
Other,
Outreach
Grant status is currently
closed, funding is a
reimbursement grant, can
be used to cover grant
application costs.
This is a reimbursement grant.
Grants are subject to the
availability of funds.
Nonprofit, using funds in rural areas
and towns with populations < 10K or
tribal lands in rural areas. Must be
used to either identify or evaluate
solutions to water storage treatment,
distribution, collection, and disposal
or tech assistance.
National
Water and
Waste Disposal
Guaranteed
Loan Program
U.S.
Department of
Agriculture
(USDA) - Rural
Development
(RD)
Loan
Federal
Private lenders may apply for a loan
guarantee on loans they make to eligible
borrowers who are otherwise unable to
obtain commercial credit on reasonable
terms.
Applications are accepted on a rolling basis.
Paper applications are accepted, or
applicants can register for and use RD Apply.
Contact your local RD office for more
information:
http://www.rd.usda.gov/contact-us/state-
offices.
http://www.r
d.usda.gov/pr
ograms-
services/wate
r-waste-
disposal-loan-
guarantees
Application
process, Loan
program,
Long-term
program
Capital
Loans serviced through
private lenders. Borrower
must have legal authority
to construct & maintain.
The maximum guarantee is
typically 90% of the loan amount.
Interest rates may be fixed or
variable as negotiated between
the lender and the borrower,
subject to USDA approval. Up to
40-year payback period, based on
the useful life of the facilities
financed.
Eligible: Most state and local
governmental entities. Nonprofit
organizations, Federally-recognized
tribes. Eligible areas are Rural and
Towns with populations less than
10,000; tribal lands in rural areas;
colonias.
National
Water
Foundation:
Grant
Water
Foundation
Grant
Private
The Water Foundation works to transform
how water is managed in the West. The
Foundation helps grantees identify and act
on opportunities to better manage water
and engage in thoughtful, strategic
grantmaking to nonprofit partners to drive
change.
Proposals are accepted by invitation only.
http://waterf
dn.org/
Grant
program,
Long-term
program
Capital, Other
Funding levels varies based on
need.
CA
60
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Water
Infrastructure
Finance and
Innovation Act
(WIFIA)
Program Loans
U.S.
Environmental
Protection
Agency (EPA)
Loan
Federal
Federal credit program administered by EPA
for eligible water and wastewater
infrastructure projects. Funds development
phase activities;
construction/reconstruction/rehabilitation/r
eplacement; acquisition of real property or
interest in real property, environmental
mitigation, construction contingencies, and
equipment acquisition; capitalized interest
necessary to meet market requirements,
reasonably required reserve funds, capital
issuance expenses, and other carrying costs
during construction.
Interested parties submit letter of interest,
which EPA evaluates for eligibility,
creditworthiness, technical feasibility, ability
to meet WIFIA strategic objectives, and
readiness to proceed. EPA scores eligible
projects using identified criteria and
develops ranked list. Projects above
threshold are invited to apply.
https://www.
epa.gov/wifia
Application
process,
Competitive
process, Loan
program
Capital, Other
Low cost-supplemental
loans. Federal assistance
cannot exceed 80% of
project's eligible cost.
$20 million: Minimum project size
for large communities. $5 million:
Minimum project size for small
communities (population of 25,000
or less). 49%: Maximum portion of
eligible project costs that WIFIA
can fund.
Eligible entities: local, state, federal,
tribal government; partnerships and
joint ventures; corporations and
trusts: Clean Water (CW) and
Drinking Water (DW) State Revolving
Fund (SRF) programs.
National
Water
Infrastructure
Fund (WIF)
Minnesota
Public Facilities
Authority (PFA)
Grant
State
Provides supplemental grants based on
affordability criteria to help communities
build wastewater and drinking water
treatment projects that replace aging
infrastructure and meet permit
requirements.
Applicants eligible for Rural Development
funding must apply directly to Rural
Development. Non-Rural Development
projects must request placement on the
Clean Water Revolving Fund Intended Use
Plan for wastewater projects or on the
Drinking Water Revolving Fund Intended Use
Plan for drinking water projects and follow
the PFA's loan application process.
https://mn.go
v/deed/gover
nment/public
facilities/fund
s-
programs/wa
stewater.jsp
Application
process,
Grant
program,
Long-term
program,
Non-
competitive
process
Capital
Provide matching grants
to communities that meet
affordability criteria and
receive PFA loans or
water financing from U.S.
Department of Agriculture
(USDA).
For municipalities receiving
funding from USDA Rural
Development (RD), the WIF grant
may be up to 65% of the total
grant need determined by USDA
RD. Municipalities not receiving
funding from Rural Development
may receive a WIF grant in
conjunction with a CWRF or DWRF
loan when the average per
household system costs exceed
1.4% of median household income
for Clean water or 1.2% of median
household income for Drinking
water projects. The maximum WIF
grant may not exceed $5 million or
$20,000 per connection,
whichever is less.
Cities, counties, townships, sanitary
districts or other governmental
subdivisions responsible for water
treatment are eligible. Must meet
USDA RD eligibility or apply directly
to PFA as part of the application for
the CWSRF.
MN
Water
Resources
Research
National
Competitive
Grants
Program
U.S. Geological
Survey (USGS)
and National
Institutes for
Water
Resources
(NIWR)
Grant
Federal
Supports research on the topic of improving
and enhancing the nation's water supply,
including (but not limited to) enhancement
of water supply infrastructure, development
of drought impact indicators, evaluation of
the dynamics of extreme hydrological events
and associated costs, development of
methods for better estimation of the
physical and economic supply of water,
integrated management of ground and
surface waters, the resilience of public water
supplies, and the evaluation of conservation
practices. Proposals are sought in not only
the physical dimensions of supply, but also
the role of economics and institutions in
water supply and in coping with extreme
hydrologic conditions.
Download the grant application at
https://water.usgs.gov/wrri/national-
competitive-grants.php.
https://water.
usgs.gov/wrri
/national-
competitive-
grants.php
Application
process,
Competitive
process,
Grant
program
Other
Successful applicants
must match each dollar of
the Federal grant with
one dollar from non-
Federal source.
$6.5 million in FY17; applicants
must match each Federal dollar
with not less than one dollar from
non-Federal sources, and states
may have different guidelines as to
the sources of matching funds.
Projects must be for one to three
year duration. Focus on water
problems and issues that are of a
regional or interstate nature.
Accredited higher learning
institutions may apply.
VA
Water Supply
and Water
Quality Grant
Funding
Programs
Northwest
Florida Water
Management
District
Grant
State
Supports projects from local governments
and nonprofit utilities that help communities
across northwest Florida meet local and
regional water supply development needs.
Funding may also be available to implement
water quality improvement projects for
springs and surface water protection.
Visit the website for more information.
http://www.n
wfwater.com
/Water-
Resources/Fu
nding-
Programs/
Application
process,
Grant
program
Funding was matched
with more than $9.4
million from grantees and
partner agencies, totaling
more than $30 million of
water supply investment
in communities across
northwest Florida.
Annual amount varies.
Projects of interest must benefit one
or more of the District's core mission
areas: water supply, water quality,
natural systems, flood protection.
FL
61
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
WaterSMART
Drought
Response
Program:
Drought
Contingency
Planning
U.S.
Department of
the Interior
(DOI) - Bureau
of Reclamation
Grant
Federal
Applicants are invited to request funding to
develop a new drought plan or to update an
existing drought plan. Applicants may also
request technical assistance from the Bureau
of Reclamation for the development of
elements of the Drought Contingency Plan.
See the WaterSMART website at
https://www.usbr.gov/watersmart/ for
information. Funding Opportunity
Announcements will be posted at
www.grants.gov. Projects must meet one of
the program goals on webpage. Must
develop within two years of receiving
funding.
https://www.
usbr.gov/dro
ught/planning
.html
Application
process,
Competitive
process,
Grant
program,
Long-term
program
Other
50% non-Federal cost
share contribution is
required (including non-
Federal funds, donations,
contributions, and/or in-
kind services). In limited
cases, a cost-share
reduction or waiver may
be granted.
FY17 funding amount: Up to
$200,000 per agreement for a
project that can be completed
within two years.
States, Indian tribes, irrigation
districts, water districts, and other
organizations with water or power
delivery authority located in the 17
Western United States and Hawaii
are eligible for this funding
opportunity.
Western
US, HI
WaterSMART
Drought
Response
Program:
Drought
Resiliency
Projects
U.S.
Department of
the Interior
(DOI) - Bureau
of Reclamation
Grant
Federal
Applicants are invited to request funding to
implement projects that will increase the
reliability of water supply; improve water
management; implement systems to
facilitate the voluntary sale, transfer, or
exchange of water; and provide benefits for
fish, wildlife, and the environment to
mitigate impacts caused by drought. Projects
that are supported by an existing drought
planning effort are prioritized.
See the WaterSMART website at
https://www.usbr.gov/watersmart/ for
information. Funding Opportunity
Announcements will be posted at
www.grants.gov. Projects must meet one of
the four goals of the program.
https://www.
usbr.gov/dro
ught/projects
.html
Application
process,
Grant
program
Capital
A 50% non-Federal cost
share contribution is
required (including non-
Federal funds, donations,
contributions, and/or in-
kind services). Two years
to complete the project
once grant awarded.
FY17 funding amounts: up to
$300,000 per agreement for a
project that can be completed
within two years or up to $750,000
per agreement for a project that
can be completed within three
years.
States, tribes, irrigation districts,
water districts, and other
organizations with water or power
delivery authority located in the 17
Western United States and United
States Territories are eligible for this
funding opportunity.
Western
US,
Territorie
s
WaterSMART
Grants: Small-
Scale Water
Efficiency
Projects
U.S.
Department of
the Interior
(DOI) - Bureau
of Reclamation
Grant
Federal
This funding opportunity is for small-scale
water efficiency projects that have been
prioritized through planning efforts led by
the applicant. Projects eligible for funding
include installation of flow measurement or
automation in a specific part of a water
delivery system, lining of a section of a canal
to address seepage, small rebate programs
that result in reduced residential water use,
or other similar projects that are limited in
scope. Those eligible to apply are states,
tribes, irrigation districts, water districts or
other organizations with water or power
delivery authority located in the western
United States or United States Territories.
See the WaterSMART website at
https://www.usbr.gov/watersmart/ for
information. Funding Opportunity
Announcements will be posted at
www.grants.gov. FY18 applications are due
July 31, 2018.
https://www.
usbr.gov/wat
ersmart/swep
/index.html
Application
process,
Competitive
process,
Grant
program
Capital
50/50 Cost sharing.
Projects must be
completed within two
years of awarding grant.
Applicants must provide a 50%
non-Federal cost-share. Award
ceiling: $75,000 (total project
construction costsshall be no more
than approximately $150,000 to
$200,000).
Eligible entities: water districts,
tribes, states and other entities.
Small water efficiency projects only.
Western
US
WaterSMART
Grants: Water
and Energy
Efficiency
Grants
U.S.
Department of
the Interior
(DOI) - Bureau
of Reclamation
Grant
Federal
This program invites states, Indian tribes,
irrigation districts, water districts, and other
organizations with water or power delivery
authority to leverage their money and
resources by cost sharing with the Bureau of
Reclamation on projects that seek to
conserve and use water more efficiently,
otherwise support water sustainability
strategies, and prevent any water-related
crisis or conflict. Used to increase the
production of hydropower, mitigate conflict
risk, other benefits to contribute to water
supply in the western US.
See the WaterSMART website at
https://www.usbr.gov/watersmart/ for
information. Funding Opportunity
Announcements will be posted at
www.grants.gov.
https://www.
usbr.gov/wat
ersmart/wee
g/index.html
Application
process,
Competitive
process,
Grant
program
Capital
Applicants must provide a
50% non-Federal cost-
share. Focus on projects
that can be completed in
two to three years.
FY18 funding amounts: up to
$300,000 for smaller projects or
up to $1 million for larger projects.
Must be an entity with water or
power delivery authority.
Western
US
62
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Weatherizatio
n and
Intergovernme
ntal Program
(WIP)
U.S.
Department of
Energy
Grant
Federal
WIP is made up of two programs focused on
state and local governments, the
Weatherization
Assistance Program (WAP) and the State
Energy Program (SEP), and two teams that
develop and deliver targeted technical
assistance and strategic initiatives to state
and local governments. Provides grants,
technical assistance, and information tools
to states, local governments, community
action agencies, utilities, Indian tribes, and
U.S. territories for their energy programs.
The funding can be used to encourage
installation of green infrastructure—such as
green roofs—as part of the weatherization
process.
Funding is provided to states, which contract
competitively with local agencies.
https://www.
energy .gov/e
ere/wipo/we
atherization-
and-
intergovernm
ental-
programs-
office
Fund
allocation to
states and
localities,
Grant
program
Capital,
Other,
Outreach
Community action
agencies, other
nonprofits, and local
governments use in-house
employees and private
contractors to deliver
services to low-income
families.
WAP funding is awarded to all 50
states and territories, which contract
with local agencies nationwide.
National
West Virginia
Clean Water
State
Revolving Fund
(CWSRF)
West Virginia
Department of
Environmental
Protection (DEP)
Loan
State
Provides funding to address water quality
problems through wastewater facility
construction, upgrades, or expansions.
Available funding options are Low Interest
Loan Program (for construction of municipal
wastewater treatment works), Agriculture
Water Quality Loan Program, or On-site
Systems Loan Program.
Projects must apply to be on the annual
priority list. Pre-bid and post-bid checklists
can be accessed on website.
http://www.d
ep.wv.gov/w
we/programs
/srf/pages/de
fault.aspx
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Repayment of loans
provides funding for
future projects. Low
interest long-term loans.
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
Eligible projects must address water
quality problems. Eligible applicants
include municipalities and public
service districts.
WV
West Virginia
Drinking Water
Treatment
Revolving Fund
(DWTRF)
West Virginia
Department of
Health and
Human
Resources
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. WV allocates portions of the 15%
set-aside for its river alert and stream gage
networks.
Applicants must first send a complete
preliminary application to the Infrastructure
and Jobs Development Council requesting a
DWTRF loan and then be approved to pursue
the proposed funding. The applicant then
applies to be included on the Project Priority
List (PPL). Application documents are
available upon request.
http://www.
wvdhhr.org/o
ehs/eed/iand
cd/DWTRF.as
P
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
WV
West Virginia
Infrastructure
Fund
West Virginia
Infrastructure &
Jobs
Development
Council
(WVIJDC)
Grant
State
Provides low-interest loans and grants to
eligible project sponsors to pay for
engineering, construction, and related soft
costs for water and sewer infrastructure
projects.
Project sponsor must submit a preliminary
application for feedback prior to submitting
a request for preconstruction engineering
services advance funding assistance .Private
companies may apply if they have a public
partner to accept the funding on their
behalf. More information can he found at:
http://www.wvinfrastructure.com/project-
dashboard/pdf/policiesGuidelines/Revised%
20Policies.pdf
http://www.
wvinfrastruct
ure.com/pc/p
olicy-
procedures.p
hp
Application
process,
Grant
program
Capital, O&M,
Other
Grants to the measure of
50% of costs, or $5,000.
Funds given $100,000
must be in the form of a
loan. Repayment of loans
provides funding for
future projects.
Eligible projects must be located in
West Virginia and be for wastewater
and water infrastructure.
WV
63
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
William Penn
Foundation:
Watershed
Protection
Grant
William Penn
Foundation
Grant
Private
Focuses on watershed protection using a
science-driven approach that is combined
with data collection, research and metrics to
measure impact. The Foundation's goal is to
better understand the baseline data,
progress over time, emerging threats,
policies, and practices that can advance
private and public watershed-protection
efforts, with an emphasis on protection of
forests; reduction of agricultural run-off and
polluted stormwater; and protection of
critical aquifers. The Foundation supports
projects that protect and restore the
Delaware River watershed's natural
environment to ensure there is an adequate
supply of clean water for generations to
come.
Applications are submitted online. Potential
applicants submit an initial inquiry and if the
William Penn Foundation is interested in
learning more about the project the
applicant will be contacted to submit a
formal proposal. Application instructions are
available at:
http://www.williampennfoundation.org/how
-apply.
http://www.
williampennf
oundation.or
g/
Application
process,
Grant
program,
Long-term
program
Capital,
Other,
Outreach
Grants range from $80,000 to $11
million.
Parties interested in the grant must
submit an initial inquiry and then be
invited to submit a full proposal.
Entities must be located in the
greater Philadelphia Region.
PA
Wisconsin
Clean Water
Fund Program
(CWFP)
Environmental
Improvement
Fund (EIF)
Loan
State
Provides financial assistance to
municipalities for wastewater and
stormwater infrastructure projects, including
those for compliance with a municipality's
Wisconsin Pollutant Discharge Elimination
System (WPDES) permit.
Identify and define the wastewater
treatment or drinking water "problem" that
needs to be corrected or prevented. This
process generally involves a joint effort of
the municipality, a consulting engineer, and
the Department of Natural Resources (DNR)
engineer in your area. Pre-Application - A
notice of Intent to Apply (ITA) & a Priority
Evaluation and Ranking Formula (PERF) must
be submitted online to DNR for each project
seeking EIF loan. The deadline for all
ITAs/PERFs is October 31 for the following
state fiscal year (SFY) funding cycle. All
ITAs/PERFs must be submitted annually
online because they will only be valid for one
state fiscal year (July 1st through June 30th).
Projects will be ranked on the Priority List
(PPL) and are eligible to apply for funding.
https://dnr.wi
.gov/aid/eif.h
tml
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Loan repayments provide
a continuing source of
funds for additional
projects.
None
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
Municipalities or local governments
can apply for infrastructure project
funding.
Wl
Wisconsin
Municipal Loan
Program
Wisconsin
Board of
Commissioners
of Public Lands
(BCPL)
Loan
State
BCPL has invested in loans to municipalities
and school districts for public purpose
projects including economic development,
local infrastructure, capital equipment and
vehicles, building repairs and improvements,
and refinancing existing liabilities to reduce
future borrowing costs.
Applications are accepted and funded
continuously. The loan process begins with
the borrower submitting a one-page Loan
Application Request Form available on the
website. Funding can usually occur within
30-45 days.
http://bcpl.wi
sconsin.gov/s
ection.asp?lin
kid=1438&loc
id=145
Application
process, Loan
program,
Long-term
program,
Non-
competitive
process
Capital, Other
Invested over $1 billion in
communities throughout
Wisconsin over the past 10 years.
Eligible entities include Wisconsin
school districts and municipalities.
Wl
64
-------
Program Name
Source
Source
Type
Agency
Description
How To Apply
Website
How Funds
are Issued
How Funds
are Used
How Funds are Utilized
Funding
Amount Min
Funding Amount Max
Funding Requirements
State
Wisconsin Safe
Drinking Water
Loan Program
(SDWLP)
Wisconsin
Department of
Natural
Resources
(DNR) and
Department of
Administration
(DO A)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures. Wl uses a portion of its set-aside
for implementation of wellhead protection
programs, including: workshops;
maintenance and redesign of data
management and mapping applications; and
Implementation of a community watershed
intervention approach to protecting drinking
water systems in priority geographic areas.
In addition, Wl uses a portion of its set-aside
to conduct large volume source water
assessment monitoring.
Application documents are available at:
https://dnr.wi.gov/Aid/EIF.html. Applicants
must first submit a notice of Intent to Apply
(ITA) and a Priority Evaluation and Ranking
Formula (PERF) before submitting a loan
application. Applicants will then be scored
and placed on a Project Priority List (PPL) and
are then eligible to apply for funding.
https://dnr.wi
.gov/Aid/EIF.h
tml
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
Wl
Wisconsin
Urban Non-
point Source
and
Stormwater
Management
(UNPS&SW)
Grant Program
Wisconsin
Department of
Natural
Resources
(DNR)
Grant
State
Offers competitive grants to local
governments. Grants reimburse costs of
planning or construction projects controlling
urban non-point source and stormwater
runoff pollution.
Applications must be submitted by April 15
of the calendar year prior to the awarded
grant start year. Application material can be
found online.
https://dnr.wi
.gov/Aid/Urb
anNonpoint.h
tml
Application
process,
Competitive
process,
Grant
program
Capital, Other
Funding levels vary. For Urban
Stormwater Planning grants, DNR
withholds 50% of eligible state
cost-share reimbursements until
final grant settlement. This
withholding amount is
automatically calculated and
deducted in the Reimbursement
Request Form (Form ID 8700-336)
based on the grant cost-share rate
and total project costs claimed in
the reimbursement request.
Eligible applicants: Cities, villages,
towns, counties, regional planning
commissions, tribal governments and
special purpose lake, sewage or
sanitary districts. List of eligible
projects on webpage. For urban non-
point source and stormwater
management.
Wl
Wyoming
Clean Water
State
Revolving Fund
(CWSRF)
Wyoming
Department of
Environmental
Quality (DEQ)
Loan
State
Loans and grants given to eligible applicants
(governmental entity or a nonprofit
corporation) to improve water quality.
Complete and submit three copies of the
CWSRF loan application forms to the Office
of State Lands and Investments. State
recommends beginning the loan application
process at least 6 to 12 months prior to
bidding the project. The State Loan and
Investment Board has final loan approval
authority; it considers loans at its regular
meetings held every two months.
http://deq.wy
oming.gov/w
qd/state-
revolving-
loan-
fund/resourc
es/2-clean-
water-state-
revolving-
fund/
Application
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other
Long term interest loans.
Repayment of loans
provides funding for
future projects.
Funding level determined by
priority, number of applicants, and
total CWSRF amount to loan.
Applicant must show they can repay
the loan and adhere to federal
environmental, social, and economic
cross-cutting requirements. Eligible
applicants are state agencies,
counties, municipalities, joint
powers, and other political
subdivision.
WY
Wyoming
Drinking Water
State
Revolving Fund
(DWSRF)
Program
Wyoming
Department of
Environmental
Quality (DEQ),
the Water
Development
Office (WDO),
and the Office
of State Lands
and
Investments
(OSLI)
Loan
State
State can use 15% program set-aside for
loans or grants to public water systems or
service providers for source water protection
(SWP) activities including: purchase land or
conservation easements; implement SWP
petition programs or incentive-based
measures; delineate, assess, or update SWP
areas; establish and implement wellhead
protection programs; and other SWP
measures.
Application documents available at:
https://lands.wyo.gov/grants-
loans/loans/drinking-water-state-revolving-
funds.
http://deq.wy
oming.gov/w
qd/state-
revolving-
loan-
fund/resourc
es/3-drinking-
water-state-
revolving-
fund/
Application
process,
Competitive
process, Fund
allocation to
states and
localities,
Loan
program,
Long-term
program
Capital,
Compliance,
Other,
Outreach
State can choose whether
and how to use the 15%
set-aside annually. Funds
can also be used to
coordinate with other
programs, e.g., develop
assessments, appraisals,
and plans to meet CWSRF
and Section 319 grant
application requirements.
Eligible activities can include
outreach, BMPs, physical barriers or
security to protect water sources,
local ordinance development, and
more.
WY
65
-------
k The Grourdwatet^^^^^b
V Association ™
NGWA
Address 601 Dempsey Road, Westerville, Ohio 43081-8978 U.S.A.
Phone 800 551.7379 • 614 898.7791 Fax 614 898.7786
Email ngwa@ngwa.org Websites NGWA.org and WellOwner.org
National Ground Water Association
Comments to
Environmental Protection Agency Environmental Financial Advisory Board
Regarding Stormwater Infrastructure Funding Task Force Recommendations to Improve the
Availability of Public and Private Sources of Funding for Stormwater Infrastructure (Section 4101,
America's Water Infrastructure Act of 2018)
Submitted: November 7, 2019; Updated December 16, 2019
Summary of Action
The USEPA Environmental Financial Advisory Board is preparing a report to improve the availability of
public and private sources of funding for the construction, rehabilitation and operation and
maintenance of stormwater infrastructure to meet the requirements of the Federal Water Pollution
Control Act, as required under Section 4101, America's Water Infrastructure Act of 2018. The Task Force
plans to deliver to USEPA a report in February 2020 on this matter.
Comments of the National Ground Water Association
NGWA supports affordable financing availability to communities to assist them in responding to
managing stormwater impact. NGWA's main concern is to adequately protect groundwater beneath
proposed stormwater infiltration facilities and, in doing so, we suggest that financing for any strategies
that consider or incorporate infiltration be conditional on designs and their implementation that address
adequate protection of groundwater quality. Each site's soil zone and geology possess unique
characteristics and value to communities, and the uses of groundwater from beneath each site may be
different and, as such, these circumstances must be taken into account in engineering natural
degradation of pollutants and protection of groundwater. Our comments below elaborate on this
concern. Attention to groundwater-protective design will affect cost of facilities which in turn will affect
financing capacity and affordability.
Stormwater as a Resource
Stormwater is a resource for capture, use and groundwater recharge that can be managed in much of
the arid western United States and elsewhere in the nation for water supply. To use stormwater for
aquifer recharge and safe water supply, federal, state and local governments and the private sector
should continue collaboration to protect groundwater and improve total water management. NGWA
appreciates EFAB's consideration of the need of communities, in particular small communities, to obtain
financing for infrastructure to properly manage stormwater. Given that 62 percent of community water
systems serving 10,000 or fewer people are groundwater supplied,1 it is crucial that stormwater reuse
methods used in these communities be proven protective of groundwater supplies. Additionally, nearly
42 million people live in communities relying on private wells.2 Groundwater is a water source needing
1 U.S. Environmental Protection Agency. 2019. Drinking Water Government Performance and Results Tool.
https://www.epa.gov/ground-water-and-drinking-water/drinking-water-performance-and-results-report
(Accessed December 10, 2019).
2 U.S. Geological Survey. 2018. Estimated Water Use in the United States in 2015. Circular 1441.
https://pubs.er.usgs.gov/publication/cirl441 (Accessed December 10, 2019).
Page 1 of 8
-------
protection for them and these systems. Small communities have few resources or expertise to protect
their groundwater sources of water supply.
Response to Urban Runoff
Uncontrolled stormwater discharges contain a variety of pollutants such as sediment, nutrients,
chlorides, pathogens, metals, petroleum hydrocarbons, and trash, and are a significant cause of water
quality impairment for surface waters.3 EPA has promoted green stormwater infrastructure as a
principal method to respond to urban runoff to be controlled under the Clean Water Act National
Pollutant Discharge Elimination System (NPDES) permitting. EPA has identified a range of methods to
mimic the hydrologic cycle in nature including: reduction of impervious areas, downspout
disconnection, rainwater harvesting, rain gardens, planter boxes, bioswales, permeable pavements,
green streets and alleys, green parking, green roofs, urban tree canopy, and land conservation.4
Effects of Stormwater Practices on Groundwater Quality
The National Research Council did a thorough review in 2008 of urban stormwater practice. The report
raised concerns about stormwater quality impacts on groundwater quality. While no specific research
recommendation was made relative to groundwater quality, it noted "To ensure that groundwater is not
compromised when surface water is routed through infiltrative practices, municipalities must establish
where appropriate conditions do and do not exist and spot infiltration opportunities accordingly"5,
pointing to a need for sound guidance. The Center for Watershed Protection's 5-year research agenda
focused on actions to protect surface waters needing attention relative to pollutants from stormwater
and did not include groundwater quality concerns.6 The International Stormwater Best Management
Practices Database Final Report maintained by the Water Environment and Reuse Foundation contained
minimal information on groundwater quality as a result of stormwater management.7 In general, there
is a lack of microbial removal performance for green stormwater infrastructure. The fecal indicator
pollutant summary noted "Where infiltration is used, it is important to recognize that groundwater
pollution can also occur, if adequate sorption and filtration do not occur prior to the infiltrated flows
reaching groundwater." While some studies of permeable pavement suggest that additional
performance reporting would be useful, other studies have shown improvement in their water quality
performance.8
3 U.S Environmental Protection Agency. 2017. Municipal Separate Storm Sewer System Permits Compendium of
Clear, Specific & Measurable Permitting Examples. EPA-830-S-16-002.
https://www.epa.gov/sites/production/files/2017-01/documents/final_compendium_intro_document_508.pdf;
4 U.S Environmental Protection Agency. 2017. What is Green Infrastructure? https://www.epa.gov/green-
infrastructure/what-green-infrastructure.
5 National Research Council. 2008. Urban Stormwater Management in the United States. The National Academies
Press, Washington, D.C., www.nap.edu.
6 Center for Watershed Protection. 2017. Five-Year Research Agenda
https://www.cwp.Org/~cwporg/Oldsite/wp-content/uploads/2015/09/cwp_researchagenda_10.18.16.l.pdf
"The goal of our research is to synthesize the best available science to develop tools that work
to protect and restore our streams, rivers, lakes, wetlands and bays."
7 Water Environment and Reuse Foundation. 2017. International Stormwater BMP Database Final Report:
2016 SUMMARY STATISTICS 2017. http://www.bmpdatabase.org/Docs/03-SW-
lCOh%20BMP%20Database%202016%20Summary%20Stats.pdf
8 Roseen, Robert M., Thomas P. Ballestero, James J. Houle, Joshua F. Briggs, Kristopher M. Houle, 2012, Water
Quality and Hydrologic Performance of a Porous Asphalt Pavement as a Stormwater Treatment Strategy in a Cold
Climate, ASCE Journal of Environmental Engineering, vol. 138, no. 1, pp. 81-89.
Page 2 of 8
-------
A review of the database results found for the more than 400 studies included that groundwater was
mentioned in summary results 30 times, while retention ponds/basins/cells were mentioned 440 times
and wetlands, 583 times. Retention structures and wetlands are typically associated with groundwater.
Even in hydrologic soil group C (sandy clay loam), infiltration can be significant.9 This observation reflects
that groundwater protection has received less attention in design and testing, while methods for
removal of pollutant loads from surface water has commanded stormwater management efforts.
Guidance to States and Communities
A review of stormwater guidance of selected federal, state and municipal governments10 with significant
groundwater and stormwater challenges found that the major concern relative to groundwater quality
was checking for "hotspots" that were already contaminated. In these "hotspot" locations, caution
should be exercised not to infiltrate stormwater to them since additional subsurface water could cause
the contamination to spread to groundwater users and to streams. Nearly all the references included
setbacks for infiltration sites to ensure that wells or other subsurface conditions or structures were not
adversely affected. Some references importantly cited the need for precautions in wellhead protection
areas to protect water supply safety. State documents provided direction on hotspots and areas of high
water tables to avoid or be setback from and on special steps to take in areas of karst and permeable
geology. Two state documents indicated that soils may exist at sites or be amended to adjust organic
matter and pH to provide pretreatment for infiltrated water that may have metals and organic
contaminants that could be adsorbed.
9 Houle, James, T. Ballestero, and T. Puis, 2018, Stormwater Runoff Study helps Determine Sizing Criteria of Control
Measures, Stormwater Management, WEF, V. 6, No. 1, Alexandria, VA.
10 City of Los Angeles (California). 2011. Development Best Management Practices Handbook; Low Impact
Development Manual, http://www.lastormwater.org/wp-content/files_mf/lidhandbookfinal62212.pdf; Maryland
Department of the Environment. 2009. Maryland Stormwater Design Manual, Volumes I and II.
http://mde.maryland.gov/programs/Water/StormwaterManagementProgram/Pages/stormwater_design.aspx;
Minnesota Pollution Control Agency. 2016. Minnesota Stormwater Manual
https://storm water, pea. state, mn. us/index. php?title=File:Contamination_screening_checklist_for_storm waterjnfi
I tration_July_2016.xlsx and Stormwater and Wellhead Protection.
https://stormwater.pea.state.mn.us/index.php?title=Stormwater_and_wellhead_protection; New York City
Department of Environmental Protection. 2012. Guidelines for the Design and Construction of Stormwater
Management Systems.
http://www.nyc.gov/html/dep/pdf/green_infrastructure/stormwater_guidelines_2012_final.pdf; Philadelphia
Water. 2017(accessed online). Stormwater Retrofit Guidance Manual.
https://www.phila.gov/water/PDF/SWRetroManual.pdf; US Environmental Protection Agency. 2009. Technical
Guidance on Implementing the Stormwater Runoff Requirements for Federal Projects under Section 438 of the
Energy Independence and Security Act. EPA 841-B-09-001. www.epa.gov/owow/nps/lid/section438 and
https://www.epa.gov/sites/production/files/2015-08/documents/epa_swm_guidance.pdf; US Environmental
Protection Agency. 2003. When Are Storm Water Discharges Regulated As Class V Wells?
https://www.epa.gov/sites/production/files/2015-08/documents/fs_storm.pdf; West Virginia Groundwater/UIC
Program. 2006. Stormwater Management Structure Guidance Document.
https://dep.wv.gov/WWE/Programs/gw/Documents/14469_gw_Stormwater_Management_Structure_Guidance_
Combined.pdf; Wisconsin Bureau of Watershed Management. 2017. Site Evaluation for Storm Water Infiltration
Technical Standard 1002. http://dnr.wi.gov/news/input/documents/guidance/TS1002Final.pdf; Wisconsin State
Legislature. 2017. Chapter NR 151, Runoff Management
https://docs.legis.wisconsin.gOv/code/admin_code/nr/100/151/lll/12/5/c.
Page 3 of 8
-------
Generally, the stormwater management guidance provided significant detail on stormwater capture,
infiltration and facility development and relatively little focus on long-term considerations for
groundwater quality which would require significant resources to deal with if degraded over time. One
state guidance specifically provided the option for monitoring groundwater that receives stormwater
infiltrate and would be used as a source of drinking water - a significant acknowledgement that the
larger hydrologic cycle being intervened with needs attention. Additionally, "EPA has set minimum
standards to address the threats posed by all injection wells, including stormwater drainage wells [which
may include dry wells, bored wells and infiltration galleries], Stormwater injection is a concern because
stormwater may contain petroleum or other organic compounds that could harm USDWs [Underground
Source of Drinking Water], Other potential harmful contaminants include: sediment, nutrients, metals,
salts, microorganisms, fertilizers, and pesticides."11
While drainage wells are regulated, they must be registered with the state to provide for control of
stormwater, but could potentially be a pathway for stormwater contaminants if regulations are not
adequately enforced. These wells could exist in rural areas as well as in urban and suburban locations.
Research on the cumulative effect of stormwater infiltration on groundwater quality is needed to
protect the resource for the future and provide further guidance to states and communities, including:
stormwater pollutant effects on groundwater in a range of subsurface environments, engineering
studies of stormwater facility hydraulics, development of monitoring approaches, and modeling
stormwater pollutant infiltration, migration and degradation. Communities should avoid moving
society's contaminants from one water source to another to avoid paying the full cost of today's water
use for near-term benefit, but potentially resulting in negative long-term consequences. We should
understand the effects and the costs and incorporate that understanding in guidance to communities.
EPA's report "The Influence of Green Infrastructure Practices on Groundwater Quality: The State of the
Science" 12 indicates that effects of stormwater infiltration on groundwater quality are largely not
understood and need research, but the EPA research program has been reduced in funding to track
groundwater quality at only three existing stormwater infiltration sites that do not reflect the
complexity of the subsurface environment and its geologic matrix across the nation. Ten research were
identified in the original EPA research plan. The intent of this research program is to provide guidance to
states and communities to protect groundwater from effects of stormwater infiltration. The subsurface
environment is complex and different from place to place, even within the same watershed.
Regulatory Process as a Basis for Incentives
In the absence of concerted efforts to protect groundwater resources when implementing stormwater
management strategies, EFAB should be encouraging stormwater BMPs that deal directly with the
source of contamination through positive financial incentives. While UIC standards in practice are
relatively limited as applied to stormwater management, disposal to shallow groundwater through Class
V "wells" should only be incentivized if the disposal by Class V wells receives authorization via the UIC
Class V program (either EPA or delegated state) using UIC standards on the quality of the injected water
so that the USDW is not "endangered."
11 U.S. Environmental Protection Agency. 2016. Stormwater Drainage Wells.
https://www.epa.gov/uic/stormwater-drainage-wells (Accessed December 10, 2019).
12 Brumley, J., C. Marks, A. Chau, R. Lowrance, J. Huang, C. Richardson, S. Acree, R. Ross, AND D. Beak. The
Influence of Green Infrastructure Practices on Groundwater Quality: The State of the Science. U.S.
Environmental Protection Agency, Washington, DC, EPA/600/R-18/227, 2018.
Page 4 of 8
-------
If a community is using UIC standards for its storm water disposal and cannot meet the
nonendangerment standard, financing should be contingent upon the USEPA granting an aquifer
exemption for the impacted aquifer/groundwater. If a delegated UIC program is in place, that program
would also review and, if appropriate, approve the aquifer exemption request and submit it to USEPA
where it will go through the aquifer exempting process laid out in 40 CFR 144.7 and 146.4. The use of an
aquifer exemption would only be appropriate if a large scale/regional Municipal Separate Storm Sewer
System (MS4) permit is involved due to the expense to the permittee and the amount of time involved
for the review and approval by the delegated authority and USEPA, which may include modeling flow,
inventorying wells that are using the same aquifer, and other key steps. If the aquifer is currently in use
or is potentially usable, the granting of the aquifer exemption would not only be in question, but
unlikely.
Stormwater Infiltration Design Approach
The vast majority of stormwater infiltration systems are not regulated under the UIC program. In
general, it is not prudent or wise to discharge polluted waters to any of our natural systems. So whether
it be stormwater discharge to surface water or to groundwater, some minimum amount of treatment
should occur first. Treatment becomes complex because some pollutants, such as chloride, are not
removed by green stormwater infrastructure. For each site and setting, a conscious effort to
understand the consequences to all receiving natural resources should occur and design the stormwater
collection, treatment and infiltration process accordingly. Ideally, this design should stem from
regulatory guidance, but in general this guidance is incomplete and mainly focuses on volume rather
than quality. A more effective approach is to reduce and/or eliminate the sources of pollution, but this
may not always be practical.
The importance of the soil zone for stormwater infiltration treatment is considerable. EPA's State of the
Science report states on pages 69 and 7013:
"The chemical interactions between surface water and groundwater are controlled by the type
of geologic materials present and the amount of time the water is in contact with these
materials. The various chemical reactions that affect the biological and geochemical
characteristics of the basin are acid-base reactions, precipitation and dissolution of minerals,
sorption, ion exchange, oxidation-reduction reactions, biodegradation, and dissolution and
exsolution of gases. It is concluded that when implementing green stormwater infrastructure for
infiltration, the properties of the unsaturated and saturated zones interacting with the
infiltrating water need to be considered. These considerations encompass the understanding of
the native soil texture, structure, and organic matter content of the unsaturated zone, as well as
considering the porosity and permeability of the saturated zone and the flow of the
groundwater. Kinetics and mixing relationships also require examination. Colloidal transport
also needs to be considered as a mechanism that can transport contaminants through the soil,
by either being a contaminant itself or having a contaminant sorb to a benign colloid. Colloids
13 Brumley, J., C. Marks, A. Chau, R. Lowrance, J. Huang, C. Richardson, S. Acree, R. Ross, AND D. Beak. The
Influence of Green Infrastructure Practices on Groundwater Quality: The State of the Science. U.S. Environmental
Protection Agency, Washington, DC, EPA/600/R-18/227, 2018.
Page 5 of 8
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can be restricted by capture, sorption and static interaction. . .. [C]olloid-facilitated transport
could be an important mechanism for the movement of contaminants into groundwater."
Any design that does not incorporate an adequate soil zone for some level of natural treatment and
bypasses this zone enables contaminants to move into the lower unsaturated zone with minimal
mitigation, potentially contaminating groundwater.
Monitoring and Modeling
Predictive methods followed by monitoring groundwater quality at stormwater infiltration sites is
important to establish groundwater quality and safety, similar to monitoring surface water effects of
discharges. Monitoring demonstrates the efficacy of the stormwater infiltration at any location.
Monitoring also provides the basis for determining if another stormwater management approach should
be considered. Monitoring is not included in most research on stormwater quality impacts to
groundwater.14 Groundwater quality effects have a significant lag time to be observed at distances
away from the stormwater infiltration site and therefore long-term effects need to be observed over
decades.15 Long-term monitoring is a necessary investment to understand the effects and how
stormwater infiltration should be modified to deal with them. Monitoring is also needed to determine
whether remediation is required for safe groundwater use. Data from monitoring can be used for
modeling stormwater effects on groundwater quality and potential costs on receptors at risk. Modeling
is a cost-effective approach for groundwater impact assessment.16
As an example, monitoring in Delaware identified eleven groundwater-supplied water systems with
wells between 75 and 450 feet deep receiving stormwater in their groundwater capture area to have
statistically significant trends of increasing chloride. Four systems have radionuclide problems due to
the high chloride concentrations. At current rates of increase, groundwater serving two systems will
reach the 250 mg/L SMCL for chloride in about 10 years. With no suitable alternative sources of supply,
these systems will need expensive treatment to remain viable. 17 While policies relating to deicing may
need attention, this example points to the interactive nature of chemicals carried by stormwater
infiltrated to the subsurface with the ability to change groundwater chemistry adversely.
Conclusions about Current Understanding of Stormwater Infiltration
• Small communities need significant attention and support for stormwater management with most
small communities relying on groundwater for domestic water supply.
• The focus of most federal and state guidance to communities is primarily on reducing the volume of
stormwater runoff, not on the effect of infiltrating stormwater on groundwater quality.
• EPA's State of Science report on green stormwater infrastructure effects on groundwater quality
indicates that effects largely are not understood and need research, but the EPA research program
has been reduced. Other research avenues should be pursued.
14 Brumley, J., C. Marks, A. Chau, R. Lowrance, J. Huang, C. Richardson, S. Acree, R. Ross, AND D. Beak. The
Influence of Green Infrastructure Practices on Groundwater Quality: The State of the Science. U.S. Environmental
Protection Agency, Washington, DC, EPA/600/R-18/227, 2018.
15 Ibid.
16 Anderson, M.P.; Woessner, W.W.; and Hunt, R.J. 2015. Applied Groundwater Modeling. Academic Press/Elsevier
Publishing, London, UK. P. 468.
17 Communication from Delaware Geological Survey, October 21, 2019.
Page 6 of 8
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• Infiltration facilities do not all provide treatment and do not all use natural soil zone treatment.
• Due to potential long-term effects on groundwater, stormwater management is an
intergenerational equity and environmental justice issue; if groundwater becomes contaminated, it
is more costly to remediate, affecting affordability of facilities to water systems already having
limited fiscal resources.
• Training and education are needed for both communities and consultants on contaminant
treatment to be addressed in design, cost and affordability of stormwater infiltration options.
• The Underground Injection Control (UIC) program under the Safe Drinking Water Act provides one
regulatory process for managing stormwater; states may have other standards that apply.
• Research is still needed on stormwater infiltration effects on large areas over the long term which
may affect types of facilities needed and their cost to be financed that in turn affects affordability.
• Surface and ground waters are one shared natural resource that deserve all the protections that can
be provided, including monitoring to ensure that intended uses can be met.
• Regardless of funding options for stormwater disposal, the approaches need to ensure that we
protect groundwater resources when implementing stormwater solutions to provide safe water
supply to communities and aquatic life relying on groundwater and its interaction with streams.
Implications for Financing Options
Financing arrangements should be conditioned on addressing design of stormwater facilities that is
protective of groundwater quality and reference the following points that will affect stormwater facility
costs that may need to be financed:
(1) Guidance to communities for engineering stormwater infiltration should clearly address, and be
revised if necessary to address, groundwater quality effects and their mitigation. Guidance must
recognize and incorporate the complexity of the subsurface and the differences in geology from
location to location, even within a community.
(2) Existing regulatory processes for underground injection control, where applicable, should be
drawn on as a first step in design if wells are used for stormwater disposal to the subsurface.
(3) Groundwater modeling can provide a view of the subsurface and the affected aquifers for
communities evaluating stormwater infiltration alternatives to project effects of stormwater on
groundwater quality.
(4) Monitoring must be a part of any stormwater infiltration project to ensure that groundwater
quality is safe for its intended use.
Basis for the Interest of the National Ground Water Association (NGWA) in Stormwater Infrastructure
Financing
NGWA, the largest trade association and professional society of groundwater professionals in the world,
represents over 10,000 groundwater professionals within the United States and internationally. NGWA
represents four key sectors: scientists and engineers, employed by private industry, by the consulting
community, by academic institutions, and by local, state, and federal governments, to assess
groundwater quality, availability, and sustainability; water-well contractors responsible for developing
and constructing water-well infrastructure for residential, commercial, and agricultural use; and the
manufacturers and the suppliers responsible for manufacturing and providing the equipment needed to
Page 7 of 8
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make groundwater development possible. NGWA's mission is to advocate for and support the
responsible development, management, and use of groundwater.
Over 42 million people in the United States rely on private wells and nearly 90 million people are served
by groundwater from community water systems. Seventy-one percent of groundwater withdrawn is for
irrigated agriculture. Additionally, forty percent of baseflow of streams is contributed from groundwater
discharge through streambeds.
NGWA views groundwater and the subsurface as a significant natural resource that should be
sustainably managed for current and future use. The subsurface environment should be considered
from an integrated resource perspective. The resources extant in the subsurface environment with
proper management can provide fresh groundwater for drinking, industrial and manufacturing
applications, food production, and ecosystem support.
A concise summary of the position of the National Ground Water Association on groundwater protection
related to potential sources of contamination is:
• Control of potential and active sources of contamination should be a national objective, reducing the
need for remediation of groundwater.
• Aquifers should be protected from degradation recognizing that nondegradation may not be
economically and technically practical in many circumstances.
• Groundwater quality should be protected for existing or potential beneficial uses.
• Methods available to control point source contamination include land-use controls while remediation
approaches should be flexible and practical to recognize different situations.
• Waste reduction, education, and technology transfer are important to protect groundwater.
• Increased scientific research can provide the basis for land-use control decisions.
The NGWA appreciates the opportunity to comment on financing alternatives, capabilities and adequacy
for stormwater infiltration.
For further information, please contact:
Charles Job, Regulatory Affairs Manager
National Ground Water Association
601 Dempsey Road Westerville,
OH 43081 cjob@ngwa.org
202-660-0060
esses;
Page 8 of 8
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NCnWA" Address 601 Dempsey Road, Westerville, Ohio 43081-8978 U.S.A.
Phone 800 551.7379 «614 898.7791 Fax 614 898.7786
V Association
Email ngwa@ngwa.org Websites NGWA.org and WellOwner.org
National Ground Water Association
Comments to the
USEPA Environmental Financial Advisory Board Stormwater Financing Task Force
December 18, 2019
The National Ground Water Association supports federal and state financial assistance to
communities needing stormwater infrastructure.
1. Response to EFAB/Stormwater Financing Task Force Recommendations: Of the EFAB
Stormwater Financing Task Force recommendations addressed on the December 18, 2019,
conference call, #2 (Educating public officials and the public on stormwater infrastructure need),
#7(g) (multiple benefits including green infrastructure projects), and #9(B) (green project
reserve) could be modified to include wording to the effect that "the design and implementation
of stormwater infiltration projects should provide adequate protection and monitoring of
groundwater quality to protect human health and minimize future remedial costs and financing
needs."
2. Factors Contributing to the Response
a. The MS4 permit program under the Clean Water Act allows infiltration of stormwater as one
technology approach using collection drains, dry wells, infiltration basins, LID and other
means to reduce discharges to surface waters, but potentially impacting groundwater
quality because there are no groundwater discharge standards or treatment required and
may result in changed groundwater chemistry and release of contaminants to
groundwater. The UIC Class V regulations might apply in some circumstances but are not
often used for municipal stormwater control. Stormwater may be used as an important
source of water for managed aquifer recharge projects.
b. The EPA review of research by EPA/Office of Research and Development has concluded that
the effects of stormwater infiltration on groundwater quality are not well understood. EPA's
own research program on this subject only started in 2015, is incomplete and has been cut
to the point of monitoring at 3 infiltration sites not representative of the variable and
complex subsurface conditions that may exist within a community nor across the country.
c. 80 percent of community water systems serving 10,000 or fewer people and nearly all
nontransient and transient noncommunity water systems are groundwater supplied with
larger surface water systems often having backup groundwater wells as an alternate source.
d. Designing and implementing stormwater infiltration projects to protect groundwater quality
may affect their cost for contaminant degradation and reduction and their affordability.
Impacts to groundwater quality may not be observed more immediately as in surface water
but, if they occur, the impacts will be costly to remediate in the longer term.
For followup, contact: Charles Job, NGWA Regulatory Affairs Manager., cjob@ngwa.org. 202-
660-0060
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Groundwater
Guest Editorial/
Stormwater Management: When Is Green Not So
Green?
by A. Scott Andres1, Thomas P. Ballestero2, and Mary L. Musick3
Current national stormwater policy may have adverse
effects on public and private water supplies. Shallow
groundwater, which is increasingly being relied on for
drinking water, irrigation, stream baseflow, and drought
relief, is now becoming a sink for unwanted stormwater
contaminants to avoid direct discharge to surface water.
This policy of infiltration without properly considering
implications for groundwater quality should be improved
so that society's contaminants are not transferred from
one water resource to another just to avoid paying the full
cost of today's stormwater management.
Stormwater regulatory programs and green infras-
tructure practices focus first on reducing pollutant loads
to surface water, with minimal consideration of pol-
lutant load diverted to groundwater. Best management
practices, which provide direct recharge, such as porous
pavement, retention ponds, shallow injection wells, as
well as agricultural and roadway drains, are commonly
used. Frequently the only design criterion for stormwater
infiltration is the infiltration rate. Infiltrated stormwater
can cany pollutants (nitrogen; pesticides; metals, oil, and
grease from road surfaces and gas stations; hazardous
waste spills; and salts used in road deicing) as well as
cause hydraulic problems (mounding, slope stability, and
subsurface flooding of infrastructure).
Governmental and professional organizations,
including the National Research Council (https://doi.org/
10.17226/12465), USEPA Underground Injection Control
Program, and Water Environment & Reuse Founda-
tion (www.werf.org), have examined the groundwater
impact issue, but issued often vague, general cautions
about the risks. For instance, the guidance for the
1 Delaware Geological Survey, University of Delaware, Newark,
DE 19716.
2University of New Hampshire Stormwater Center, 238 Gregg
Hall, Durham, NH 03824.
3Corresponding author: Consulting Geologist, Ground Water
Protection Council, 1G05 Flite Acres Rd., Wimberley, TX 78676;
mmusick@gwpc.org
©2018, National Ground Water Association,
doi: 10.1111 /gwat.12653
Underground Injection Control program only notes that
infiltration through stormwater drainage wells has the
potential to adversely impact groundwater supplies.
State and local stormwater infiltration guidance typically
focuses on avoiding "hotspots" already contaminated so
as not to move contaminated groundwater in unanticipated
directions.
Most guidance documents recommend fixed-distance
setbacks for infiltration sites instead of empirically deter-
mined or engineered structures to preclude adverse sub-
surface effects. While these structures may initially
function as designed, without guidance and implemen-
tation of routine maintenance, they will not continue to
do so. Guidance and regulation rarely include mention of
groundwater monitoring. We understand that USEPA is
starting to identify some key concerns regarding ground-
water impacts. These include recognizing aquifer com-
plexity and long-term groundwater monitoring needs near
stormwater facilities.
Finally, using shallow groundwater for the disposal
of todays' stormwater problems may only be delaying
a problem rather than solving it. Hydraulic loading by
managed stormwater infiltration can overload natural
treatment processes. Impacted groundwater can ultimately
discharge to surface waters resulting in long-term degra-
dation, especially under low flow conditions. This concept
was recently addressed in a U.S. Ninth Circuit Court
of Appeals decision (February 1, 2018, Hawaii Wildlife
Fund v. County of Maui). The panel found that the dis-
posal wells were "point sources" that discharged "pollu-
tants" into groundwater, that eventually entered surface
water and therefore these wells fell under the purview
the National Pollutant Discharge Elimination System. On
February 20, 2018, the U.S. Environmental Protection
Agency issued a request for comment regarding the ade-
quacy of its regulatory programs under the Clean Water
and Safe Drinking Water Acts addressing stormwater dis-
charges to groundwater "in direct hydrologic connection
to surface water" (83 FR 7126 comments due May 21,
2018).
NGWA.org
Vol. 56, No. 3-Groundwater-May-June 2018 357
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With the complexity of the subsurface, a single
approach to managing stormwater infiltration and protect-
ing groundwater quality will not be appropriate. Most
guidance documents do note that additional research
into groundwater contamination is warranted. Scientific
research is needed to identify less risky stormwater infil-
tration practices, quantify impacts on groundwater quality
and quantity, develop appropriate monitoring practices,
improve pollutant removal prior to infiltration, and discern
sound hydrogeologic Slid engineering design practices in
the siting and design of stormwater facilities. Research
is also needed to understand the future effects and costs
of stormwater disposal practices and to develop a more
advantageous and desirable policy for all water users.
358 Guest Editorial Groundwater 56, no. 3: 357-358
N6WA.org
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The Influence of Green Infrastructure Practices on
Groundwater Quality: The State of the Science
I Contact
i
j National Risk Management Research Laboratory.
https://www.epa.gov/aboutepa/about-national-risk-management-research-
i laboratory-nrmrl
Citation:
Bruin ley, J., C. Marks, A. Chau, R. Lowrance, J. Huang, C. Richardson, S. Acree,
R. Ross, AND D. Beak. The Influence of Green Infrastructure Practices on
Groundwater Quality: The Stale of the Science. U.S. Environmental Protection
Agency, Washington, DC. EPA/600/R-18/227, 2018.
Impact/Purpose:
Green infrastructure (GI) is increasingly being used to manage urban slormwater
runoff. How the soils and subsurface geology/sediments interact with the
stonr,water runoff constituents has received little attention and the possible risks
of groundwater quality impairment is poorly understood. The goal of literature
review is to provide the current understanding of potential impacts or impacts to
groundwater quality that could result from the use of GI to manage stormwater
runoff. The results of the literature review were mixed; in some cases, there were
impacts or potential impacts, and in other cases there were no impacts found.
Many of the studies' results were problematic. In most cases, the results-
reflected only what occurs in the vadosc zone or the infrastructure—were
extrapolated to predict what may occur to the groundwater. This extrapolation
ignores other processes that coufd facilitate the transport of contaminants to the
groundwater, such as preferential flow. In other cases there was no attempt made
to measure concentrations of contaminants in aquifers or deeper in the vadose
zone, and therefore, no definitive evidence for changes in groundwater quality.
These results indicate that more research is needed to address potential risk of
groundwater contamination that could result from the use of GI. These results will
-------
inform decision makers in EPA Office of Water, EPA Regional Staff, States and
Local Governments of the potential for groundwater impacts resulting from the
use of GT for stormwater management.
Description:
Green infrastructure (GI) technologies applied to stormwater are developed to
mimic natural infiltration and hydrologic processes. GI is a design strategy that
enhances runoff storage volume, infiltrates runoff, and contributes to groundwater
recharge. Urban development often leads to the removal of vegetation and soil,
and replacing them with large stretches of impervious surfaces. This disturbance
of the natural hydrologic cycle due to urbanization is closely connected to
deteriorating urban water quality and enhanced flood risks. When GI is used for
urban runoff, there are concerns as lo how the soils and subsurface
geology/sediments interact with the stormwater runoff constituents, thus
providing possible risks of groundwater quality impairment. Groundwater can be
contaminated by many constituents: nutrients, metals, dissolved minerals,
pesticides, other organics, and pathogens. This review provides insight into the
current slate of knowledge of the influence of GI on the subsurface environment
and groundwater. All types of GI were assessed, both surface and subsurface
infiltration infrastructures from peer-reviewed literature, published reports, and
conference proceedings. Issues addressed include: 1) pollutant risks that need
further research, 2) new infrastructure that has not been researched in depth, and
3) determining local considerations when planning for green infrastructure. When
managing water resources, the tendency for contaminants to move between the
ground and surface water needs to be considered. This requires an understanding
of the native soil characteristics in the unsaturated zone and saturated zone as well
as the hydrology. The primary geochemical processes that need to be considered
as stormwater infiltrates are dissolution and precipitation, redox, ion exchange,
adsorption/desorption, complexation/chelation, kinetics, mixing relationships, and
colloid-facilitated transport. Simulation models are a potentially affordable way to
predict risk as well as provide a decision-making tool for implementing GI. While
many models are used to assess surface water and groundwater transport, few
integrate GI; those that do integrate GI do not address groundwater contaminant
transport. The biology of the system can have various impacts. Microorganisms
such as bacteria, viruses, and parasites can be a contamination risk depending on
the unsaturated and saturated zone conditions, incubation time, and native
microbial populations. Macrobiological organisms can enhance or cause
complications for green infrastructure, but research on these is limited. Riparian
zones do not have any studies specific to urban GI, but previous studies on
riparian zone restoration show7 they could restore denitrification to urban streams,
induce recharge, and serve as a less manipulative approach for enhancing
infiltration into alluvial groundwater. Overall, a better understanding of the risks
associated with GI is needed to recognize the implications of GI on a longer
temporal scale and wider spatial scale. When implementing GI. the local geology,
climate, hydrology, biology, geochemistry, type of infrastructure, and contaminant
loads need to be carefully considered to reduce risks to groundwater.
URLs/Do wn loa ds:
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ORD-O?742fi F.PAfiOOR.187-27 508.PDF (POENApp, 6350,325 KB, abom
PDF)
Record Details:
Record Type: DOCUMENT (PUBLISHED REPORT REPORT)
Product Published Date: OS.31.20IS
Record Last Revised: 10/09/2018
OMB Category: Other
Record ID: 342610
Show Additional Record Data
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EPA/600/R-18/227
August 2018
The Influence of Green Infrastructure
Practices on Groundwater Quality:
The State of the Science
by
Jessica Brumley , Christopher Marks , Alexis Chau ,
Richard Lowrance , Junqi Huang , Cassie Richardson ,
Steven Acree , Randall Ross , and Douglas Beak
NRC Post Doctoral Research Associate
Ada, OK 74820
U.S. Environmental Protection Agency
Office of Research and Development
National Risk Management Research Laboratory
Ada, OK 74820
ORAU Student Contractor
Ada, OK 74820
Environmental Research Apprenticeship Program
Ada, OK 74820
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8.0 Conclusions/ Future Research Needs
8.1 Conclusions
Stormwater reclamation for eventual reuse is triggering a paradigm shift from stormwater seen as a
contaminant and a flood risk to a resource that can solve these risks. GI design strategy retains storage,
infiltrates runoff, and contributes to the renewed groundwater recharge to more closely resemble the
hydrology before urban development. The disturbance of the natural hydrologic cycle due to
urbanization is closely connected to deteriorating urban water quality. This creates an increased risk to
groundwater quality because of new pathways for contaminant introduction into groundwater, chemicals
associated from anthropogenic activities, and wastewater exposure. This literature review determined
what research that has been done on GI practices with respect to groundwater quality and the risks and
impacts to the subsurface environment. The issues addressed include: 1) contaminant risks that need
further research, 2) new infrastructure that has not been researched in depth, and 3) determination of
local considerations when planning for green infrastructure.
Any pollutant found in stormwater could be a potential groundwater contaminant when used with GI
infiltration technology. GI can return the urban hydrology to a more natural hydrologic cycle through
retention and infiltration methods. Surface and subsurface infiltration can influence the impact the
infiltrating stormwater has on the groundwater chemistry. Retention techniques can influence the water
table depth through mounding, which have been seen in restoration projects, bioretention cells, and
regenerative stormwater conveyance systems. Concern with GI for stormwater infiltration include
fluctuations in groundwater levels, limitations with large precipitation events, clogging, and soil
limitations. The infiltration is dependent on the clogging rate of the infrastructure.
Depending on the water's chemical, biological, and physical conditions, there is the risk of potential
contaminants leaching from native soils and geology. When it comes to managing water resources, the
tendency for contaminants to move between the ground and surface water needs to be considered.
Urbanization can introduce contaminants that are otherwise not an issue in natural stormwater
hydrology. Groundwater can be contaminated by many constituents: nutrients, metals, dissolved
minerals, pesticides, other organics, and pathogens; the sources of which include residues from
automobiles, lawn treatments though fertilizers and pesticides, sewer overflows, and road deicing salts.
Due to risks affecting groundwater quality, it is suggested that infiltrating GI not be implemented in
areas with potentially high contaminant loading, i.e. recycling centers, gas stations, and brownfields.
When infiltrating devices are installed and used for urban runoff, there are concerns as to how the soils
interact with the stormwater runoff pollution while infiltrating into the subsurface, thus providing
possible risks of groundwater quality impairment from areas with potentially high contaminant
concentrations.
The chemical interactions between surface water and groundwater are controlled by the type of geologic
materials present and the amount of time the water is in contact with these materials. The various
chemical reactions that affect the biological and geochemical characteristics of the basin are acid-base
reactions, precipitation and dissolution of minerals, sorption, ion exchange, oxidation-reduction
reactions, biodegradation, and dissolution and exsolution of gases. It is concluded that when
implementing green stormwater infrastructure for infiltration, the properties of the unsaturated and
saturated zones interacting with the infiltrating water need to be considered. These considerations
encompass the understanding of the native soil texture, structure, and organic matter content of the
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unsaturated zone, as well as considering the porosity and permeability of the saturated zone and the flow
of the groundwater. Kinetics and mixing relationships also require examination. Colloidal transport also
needs to be considered as a mechanism that can transport contaminants through the soil, by either being
a contaminant itself or having a contaminant sorb to a benign colloid. Colloids can be restricted by
capture, sorption and static interaction. As discussed previously, colloid-facilitated transport could be an
important mechanism for the movement of contaminants into groundwater (de Jonge et al., 2004).
The potential and actual impacts to groundwater quality as the results of GI practices were reviewed.
The results presented were mixed; in some cases, there were impacts or potential impacts, and in other
cases there were no impacts found. Many of the studies' results were problematic for several reasons. In
most cases, the results—reflecting only what occurred in the vadose zone or the infrastructure—were
extrapolated to predict what may occur to the groundwater. This extrapolation ignores other processes
that could facilitate the transport of contaminants to the groundwater, such as preferential flow. Since
there was no attempt made to measure concentrations of contaminants in aquifers or deeper in the
vadose zone, there is no definitive evidence of changes in groundwater quality.
In studies that did include groundwater monitoring, it is unknown in some cases if the sampling strategy
would detect changes in groundwater quality. Information on groundwater flow direction was not
included, therefore the relationship of monitoring points to the potential transport of contaminants could
not be ascertained. Another potential problem was that the studies did not account for lag between the
time of water infiltration and the time it takes to transport the infiltrated water to the aquifer. In most
studies, that sampling occurred at or very close to the precipitation event. Because lag time was not
considered, transient changes to groundwater quality were not accounted for, even in systems that were
monitored for decades.
The only system that consistently showed impacts to groundwater quality was ASR. The ASR impacts
fell into one of two categories: unintended consequences, or the mixing of two waters with different
composition and characteristics.
Simulation models can be an affordable way for predicting quality and quantity changes, as well as a
decision-making tool for implementing green infrastructure. While there are many models in use for
surface water and groundwater transport, there are few that integrate green infrastructure, and those that
have do not address groundwater contaminant transport. Green infrastructure models have been
implemented in various formats, but none specifically addressed groundwater contamination from this
infrastructure. Problems associated with implementing models for assessing green infrastructure
technologies and influence on groundwater include the amount of data available for calibration and
validating these models, indicating a need for more field research to obtain this data.
Microbiological organisms such as bacteria, viruses, and parasites can be a contamination risk
depending on the unsaturated and saturated zone conditions, incubation time, and native microbial
population behavior. Microbial contaminants are a concern primarily if they present a public health
threat from consuming contaminated groundwater, with the most common waterborne disease being
acute gastrointestinal illness. While gut-associated microbial contaminants are not expected to grow and
thrive within the groundwater environment, their rates of removal are affected by several, often
interdependent, environmental factors. Research has shown there is a general trend of differential
survival for the various contaminant organism types. Viruses tend to have the longest persistence times
within any groundwater environment; enteric eukaryotes (iCryptosporidium spp. and Giardia spp.) and
enteric bacteria typically have die-off rates of five to ten times, and over one hundred times larger than
enteric viruses, respectively. Pathogen removal or die-off rates are typically reported based upon first
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order decay models; however, field and laboratory experiments have shown that biphasic models better
approximate the removal behavior of fecal eukaryotes and viruses within groundwater systems. Hence,
these studies have shown that there is an initial rapid removal phase for the first few days after
introduction, followed by a slower phase two to hundreds of times less than the initial phase that can
lead to months or years of persistence.
In saturated zones, factors influencing pathogen survivals in groundwater are temperature, water
chemistry, and biological processes. Aquifer hydrogeology can influence the mechanical filtration,
adsorption, wedging, and straining processes that can remove pathogens. There is also the potential of
competition for nutrients and predation by indigenous microorganisms can play a significant role in the
removal of introduced enteric pathogens. In unsaturated zones, the same processes from the saturated
zone can apply but the air phase within the unsaturated zones can create two new interfaces, air-water
and air-sediment that do not exist in saturated conditions which can both adsorb and entrap organisms.
The decreased moisture can subject microorganisms to die-off or inactivation through desiccation. The
highest native microbial populations are going to be in the rooting zone of the soil profile. Below the
rooting zone, microbial populations and activity decrease with depth.
Macrobiological organisms can enhance or cause complications with green infrastructure. Vegetation is
often used to retain nutrients and metals, enhance ecosystem service, increase filtration, and mimic the
natural hydrology. The selection of the plants is important because they need to survive potentially toxic
contaminants and the perturbations of the GI systems. There are few studies on how various
macroorganisms can influence the green infrastructure. Bioturbator species that live in the sediment can
increase the possible risk of nutrient contamination, and burrowing activity of worms can increase the
macropores in the sediment and influence the infiltration. Macrobiological organisms can enhance or
cause complications for green infrastructure, but research on these effects is limited.
Urban riparian zones can function as green infrastructure, but few studies have been done on their
influence on groundwater. Previous studies on riparian zone restoration show that they could be useful
to restore denitrification to urban streams. By serving as "natural filtration," the practice may have
beneficial effects on surface water if the water is discharged back to surface sources. This induced
recharge can also be used for either drinking water supply or to re-water floodplains. This is also a less
manipulative, more feasible way to create opportunities for filtration into alluvial groundwater.
8.2 Future Research
Analogous to what the Pitt et al. (1999) and the recent Kabir et al. (2014) reviews concluded, we concur
that more research is required to understand the potential groundwater quality impacts that can result
from the implementation of GI. Apart from conservative chemical species such as chloride, a more
complete understanding of what conditions are likely to cause groundwater quality impairment is
necessary to mitigate or prevent these potential impacts. This review also indicates there is an apparent
risk to the vadose zone "quality." Stormwater infiltration is causing the soil and vadose zone sediments
to degrade, and the potential future impacts and risks to groundwater quality because of this are
unknown—making long-term GI studies crucial.
Since land use and environmental conditions are likely to change, future groundwater risks are possible
at many current GI sites if the infrastructure is not properly maintained. Further research is needed to
determine the best monitoring methods for groundwater at these sites throughout their lifetime.
Changing conditions will likely change the chemical and physical properties which can alter the
retention properties in the soil/vadose zone. These potential land use changes and maintenance problems
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need to be addressed in future research. Another issue encountered is that, once the GI system is no
longer functional or is "decommissioned," what practices should then be implemented to mitigate the
potential environmental issues created by trapping the contaminants in the vadose zone. This emphasizes
the need for long term monitoring methods that addresses placement of sampling points and timing of
sampling to determine the long-term impacts to the subsurface. Currently GI performance standards are
not included into the National Pollutant Discharge Elimination System (NPDES) permits, including
impacts on groundwater. Including this into the NPDES system may be benefitial to protection
groundwater quality.
Additional research is needed to understand the impacts and benefits that various macrobiological
organisms have on GI, and how these affect the hydrology, fate, and transport of contaminants in GI
systems. Vegetation is the most common addition to GI, but there is an inadequate understanding as to
how this vegetation influences groundwater quality over time. Addressing whether preferential flow
increases over time or if nutrient and metal concentrations change over time is a necessity. Previous
studies on riparian buffer zones have shown various benefits to restoring these in non-GI situations, but
further studies are needed to determine the benefits and potential issues with implementing them as part
of urban GI.
Simulation modeling of GI systems needs to be addressed to help users understand the potential
groundwater impacts. Further research of simulation models is needed to address the location and
spacing of GI stormwater practices to determine if there are diminishing returns on the quantity of
stormwater controls. Simulation models are necessary to determine how large GI projects can be
designed to effectively reduce runoff and have the least environmental impact (Brown et al., 2012;
Eckart et al., 2017). Research on the use of models to demonstrate how GI performs under different
temporal scales, spatial scales, and climatic conditions is needed since there is a lack of data on the
performance of these technologies. Simulation research and improvements in modeling techniques are
also needed so that they can assist in understanding the role of GI in restoring the water balance,
reducing contaminants over the long term, evaluating various GI performance, as well as acting as
decision support tools (Dietz, 2007; Ahiablame et al., 2012; Fletcher et al., 2013; Eckart et al., 2017).
Overall, there are several research areas necessary for a better understanding of the risks of a GI
infiltration technology that have been proposed as the result of this effort. There needs to be more
investigations looking at the GI interactions on a longer temporal scale and wider spatial range. When
implementing GI, the local geology, climate, hydrology, biology, geochemistry, type of infrastructure,
and contaminant loads need to be carefully considered to reduce the risk to groundwater quality.
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February 7, 2020
TO THE MEMBERS OF THE U.S. HOUSE OF REPRESENTATIVES:
RE: Alternative Compliance and Stormwater Innovation Coalition Principles
Communities and industry are facing significant challenges in complying with water quality
requirements related to stormwater management. Stormwater infrastructure is aging, and in many
cities, maintenance has been deferred. EPA estimates that funding needs for stormwater
management and projects to correct sewers that overflow will total $106 billion over the next 20
years.1 As investments in modernizing water infrastructure are made, there are opportunities to
capitalize on the multiple benefits of combining green and gray infrastructure that often costs
less while accomplishing more.
The U.S. Chamber of Commerce Business Task Force on Water Policy has established a multi-
stakeholder coalition of companies, water sector associations, open space and parks
organizations, municipalities and public utilities holding NPDES permits, and environmental
NGOs dedicated to the following principles:
• Recognize stormwater as a water sector category at the same level as drinking water and
wastewater. This approach should be reflected in all funding and policy decisions. The
American Society of Civil Engineer's (ASCE) decision to include stormwater as a new
category in its 2021 Public Infrastructure Report Card underscores this priority. The value
proposition includes:
o Ensuring public and private investment in stormwater infrastructure and management,
o Recognizing the significant water quality and quantity impacts,
o Promoting positive environmental and economic outcomes from advancements in
stormwater management.
• Promote the use of green infrastructure. Green infrastructure uses vegetation, soils, and other
elements and practices to restore some of the natural processes required to manage water and
provide multiple benefits to create healthier urban environments.2 It should be made an
explicit alternative to meet stormwater requirements and receive federal funding (e.g.,
CWSRFs, WIFIA, and LWCF). The group suggests evaluating barriers and opportunities to
encourage the use of these federal programs for this purpose.
o Established and early-stage equipment and technology companies are rapidly
innovating new approaches to manage stormwater flow that can often be deployed
more rapidly and are less expensive than traditional approaches, especially when
combined with green infrastructure. Federal, state, and local laws should promote the
1 https://fas.org/sgp/crs/misc/R43131.pdf2 https://www.epa.gov/green-infrastructure/what-green-infrastructure
2 https://www.epa.gov/green-infrastructure/what-green-infrastructure
1
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use of such smart or digital solutions. The federal government should also explicitly
support the export of such products and services into international markets,
o Rainwater harvesting systems, structural soil systems, and permeable pavements,
among other technologies, should be incentivized, especially in urban and densely
populated areas.
o Parks and open space should be included as essential infrastructure options to
implement green infrastructure,
o Provision of an additional source of secondary or tertiary treated water through
rainwater harvesting and other green infrastructure solutions is increasingly important
as water resources become more constrained. Green infrastructure systems, including
parks and open spaces, that hold and slow stormwater surges also allow for extra
water storage during big storm events, increase resilience, reduce flooding, and lower
risks for companies and communities.
• Incentivize alternative compliance approaches. Partnerships between businesses that need
stormwater solutions to meet their industrial permit requirements and cities that often lack
funding to maintain and modernize infrastructure provide an opportunity for innovative
approaches to alternative compliance and still meet water quality standards. Market-based
mechanisms and community public-private partnerships should serve as examples. More
programs like these should be encouraged and clarified through regulatory guidance and
legislative language and collaboration with state and local governments.
• Allow and promote innovative funding. Businesses that do not have adequate space or
capacity to capture and treat stormwater before discharge could pay into a mitigation bank
fund that would leverage public resources. These pooled resources would create regional
green infrastructure and/or water reuse projects to benefit multiple stakeholders and improve
overall water quality and/or water supply in a location that could have significant
environmental impact.
Another funding approach is to expand partnerships to address multiple benefits of green
stormwater projects and reduce the capital costs to individual partners by attracting more
sources of funds. Multiple partners reduce costs to all involved, including utility districts that
can keep rates lower for ratepayers. Various governance structures to promote neighborhood-
scale solutions, including community-based public-private partnerships3, management
districts, and Opportunity Zones, should be included and leveraged.
o Increase funding for stormwater infrastructure and diversify funding options.
Historically, less than 5% of CWSRF assistance goes toward urban stormwater
3 https://www.epa.gov/G3/financing-green-infrastructure-communitv-based-public-private-
partnerships-cbp3-right-vou
2
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infrastructure.4 With a recently estimated funding gap in the stormwater sector of $7.5
billion annually5, and considering the rising significance of urban runoff impacts,
additional funding avenues are needed at all levels of government to adequately
address current and future investments in the stormwater sector. Fewer than
one-third of regulated MS4s in the U.S. have a dedicated funding source for needed
and ongoing stormwater infrastructure investments.6 Even for the majority of those
agencies with dedicated funding sources, that funding is insufficient to address all
needs.7 This lack of annual revenue limits the potential for needed maintenance
programs in stormwater. Funding targeting long-term operations and maintenance in
stormwater would help address the greatest need in the sector.
• Foster the use of certified professionals for green infrastructure operations, maintenance,
and monitoring. Consideration should be given to green infrastructure projects applying for
federal funding, including a plan for operations and maintenance and the use of certified
professionals (e.g., Envision, SITES, and Water Environment Federation NGICP).
Monitoring provides a feedback loop to verify results.
• Support the use of tested and verified stormwater products and practices. State, regional, and
national programs have been established to provide a forum to test and verify the
performance of stormwater technologies and products. Today, two states (New Jersey and
Washington) have testing and verification programs that are used across the country. A
national program, such as the Stormwater Testing and Evaluation for Products and Practices
program8, to expand these efforts would benefit state and local programs, permitted entities,
and land developers that can make informed judgments on the use of tested/verified
technologies. This program is targeting both proprietary, manufactured devices and public
domain solutions, including green infrastructure.
• Recognize good neighbors: Dischargers, whether cities or businesses that meet water quality
permit limits within a specified time, implement agreed-to alternative compliance
approaches, and engage the public, should receive certain protections from citizen lawsuits.
• Integrate early and often. By supporting policies that encourage cities to integrate their work
across the public and private sectors, more comprehensive, effective, and less costly green
infrastructure systems can be implemented.
• Invest in research on stormwater infrastructure program effectiveness. Considering the
potential impacts on health and human life, as well as continued environmental degradation,
4 http://stormandstream.com/wp-
content/uploads/2016/10/BNA Green Infrastructure Financing October 2016.pdf
5 https://wefstormwaterinstitute.org/wp-content/uploads/2019/08/MS4-Survev-Report-2019.pdf
6 https://digitalcommons.wku.edu/cgi/viewcontent.cgi?article=1000&context=seas faculty pubs
7 https://digitalcommons.wku.edu/cgi/viewcontent.cgi?article=1000&context=seas faculty pubs
8 https://wefstormwaterinstitute.org/programs/stepp/
3
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further research is needed to address the many challenges in reducing runoff-driven
pollution. Establish national funding standards for stormwater research that are
commensurate with accepted standards relative to the total public and private investment in
stormwater management.
• Focus on efforts to enhance community and business resilience. Credit rating agencies are
starting to consider lack of resiliency planning when determining the creditworthiness of
communities. This trend reflects the concern associated with predictions suggesting that the
total annual cost to 136 of the world's largest coastal port cities owing to coastal flooding
could reach $1 trillion by 2050.9 Losses to public infrastructure and economic activity in the
private sector will likely continue to grow if resiliency planning is not adopted. Support to
enable multidimensional stormwater infrastructure and for planning through resilience-
focused funding programs and technical guidance should be considered.
• Support programs that capture shifting precipitation patterns. The frequency and intensity of
precipitation patterns and extreme weather events are shifting in many regions across the
U.S. More funding should be provided to NO A A for programs, including Atlas 14 and the
National Water Model, to offer companies and communities more accurate and consistent
precipitation and impact data.
Thank you for your attention to these principles. We stand ready to assist Congress in its
important work of modernizing and building more resilient and sustainable stormwater
approaches for communities and companies nationwide.
Sincerely,
American Council of Engineering Companies
American Society of Civil Engineers
City Parks Alliance
Ecological Restoration Business Association
National Municipal Stormwater Alliance
U.S. Chamber of Commerce
Water Environment Federation
9 https://www.climatecentral.org/news/floods-mav-cost-coastal-cities-60-billion-annuallv-bv-2050-16356
4
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Consultation on Financing and Governance
Options for Backhaul of Hazardous Waste
from Remote Alaska Communities
Environmental Finance Advisory Board
February 12, 2020
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EFAB Charge Questions - Phase 1
1. Fee-based Programs: What are the best metrics to assess a service fee
knowing the unique circumstances and constraints of the backhaul
program? Are there other factors that should be considered when designing
a fee-based program such that we minimize program administrative costs
and maximize village contributions?
2. Financing and Funding Options: Are there other financing or funding
options that should be considered beyond a fee? This can include exploring
recycling as a commodity, creating a business model or a shared cooperative
system.
3. Involving Outside Entities: Are there opportunities to involve outside
entities, such as the federal government, industry, or product producers, in
paying for backhaul? What might these opportunities look like? 2
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Phase 2 Backhaul Alaska Consultation
Desired Outcome
EFAB will provide financial and organizational advice to ensure the
Backhaul Alaska organization is both fiscally sound and resilient to
financial and other challenges.
Discussion on finance and governance in three key areas:
1. Structure
2. Organization and Administration
3. Finance and Sustainability
Product
Summary of consultation discussion
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January 30, 2020 Briefing Webinar Topics
Background
• Rural Alaska
• Government and Key Entities
• Cost of Living
• Why is Hazardous Waste Backhaul in
Rural Alaska Important?
Program Information
• Alternative Options
• Backhaul Program Basics
• Potential Funding Sources
-------
Questions Raised
•What is EPA's role?
•For the problem, is solution too top down?
•What is the role for native organizations?
•Why are admin costs high, shipping costs low?
-------
Collaborative Effort
Solid Waste Alaska Taskforce
Alaska Department of Environmental Conservation
Alaska Native Tribal Health Consortium
Kawerak, Inc.
Zender Environmental Health and Research Group
Funding
BIA
EPA
US DOT PHMSA
Denali Commission
Engagement
Tribes, municipalities, regional tribal organizations
Air carriers, barge companies, recyclers, associations
University of Alaska
State and Federal agencies
-------
Over 200 Alaskan
Tribes and Tribal
Consortia have
funding though
EPA's Indian
Environmental
General Assistance
Program (GAP)
Funding per tribe is
inadequate to cover
needs
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-------
-------
Entities in Alaska
Layers of Government
• 114 Municipal Governments
• 229 Federally Recognized Tribes
• 19 Boroughs
•State: Legislative, Judicial, and Executive Branches
Alaska Native Claims Settlement Act (ANCSA)
• 12 Alaska Native Regional Corporations
• 12 Alaska Native Regional Non-profit Organizations
• 200 Alaska Native Village Corporations
-------
Implementation Plan
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
1
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Pilot Phase Initial Program Self-Sustaining
¦ ' ' ill ; • ¦ I "« =" , ,i" ' "'i 1 1 11
• Fees from contributors to the backhaul waste stream
• Recycling income
• Donations from industry in-kind services in-village and
regional entities
• Exploring Extended Producer Responsibility program
•
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1
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-------
Pilot 1 Complete
Pilot 1 Communities
Interior
1) Arctic Village
2) Venetie
3) Nulato
Norton Sound
4) Golovin
5) Unalkleet
6) Alakanuk
Western
7) Chefornak
Bristol Bay/Lake & Penn
8) Ekwok
9) New Stuyahok
10) Koliganek
Aleutians
11) Unalaska
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Total for 2019
Category
Lbs
E-scrap
27,180
Lead Acid
45,108
UW Lamps
956
TOTAL
73,244
l
Removed from Environment
21,000 lb plastics containing flame
retardants and PFAS
32,000 lb Lead
71 lb Mercury
1 lb Arsenic
7 lb Cadmium
5 lb Chromium
24 lb Barium
12 lb Beryllium
-------
Pilot 2 Backhaul Summer 2020
Pilot 2 Communities
Northwest Arctic
1) Noorvik
Norton Sound
2) Shaktoolik
3) St. Michael
Western
4) Scammon Bay
5) Hooper Bay
6) Kwigillingok
Bristol Bay/Lake & Penn
7) lliamna
8) Ugashik
9) Port Heiden
10) Chignik Lagoon
Kodiak
11) Port Lions
12) Ouzinkie
13) Larsen Bay
14) Old Harbor
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Anticipated Total for 2020
Category
Lbs
E-scrap*
61,695
Lead Acid**
84,760
UW Lamps***
2,740
TOTAL
149,195
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Backhaul Alaska
Pilot Program
Organizational
Chart
Regional
Coordinators
Village
Coordinators
(Pilot 1 & 2 Villages)
Executive
Committee
Statewide
Coordinator
Backhaul AK
Advisory
Committee
13
-------
Projected Costs (preliminary estimates)
IH
Program Operations
$
785,825
$ 1,136,169
Recycling, shipping
$
51,107
$ 557,869
Direct village investment
$
181,752
$ 1,673,716
Administration Indirect
$
101,868
$ 336,775
Total
$ 1,120,552
$ 3,704,529
Number of villages
17
162
Per village backhaul costs
$
65,915
$ 22,867
Per person backhaul costs
$
218
$ 66
Note: Program operations include state and regional coordination, training, outreach.
Village investment includes supplies, labor, O&M
14
-------
Pilot Program Feedback
'Good afternoon, I just wanted to let you know the trailers that arrived
were the best we have ever seen...Thank you for all what a difference
you have made!!." - Recycling Vendor
-------
Extended Producer Responsibi lity (EPR) In
Alaska?
Solid Waste Alaska Taskforce (SWAT) convened a workgroup to
develop an Extended Producer Responsibility Program white paper
Would likely require state legislation
Generally EPR programs are developed product by product
SWAT's program proposal focuses on e-waste
Could bring in new funding for e-waste recycling not only for rural
community backhaul, but also for recycling industry in urban
centers
ALASKA NATIVE
TRIBAL HEALTH
CONSORTIUM
KAYVKRAK, INC.
Zernder
Envi ran merits
16
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Consultation
-------
Agenda
Session Orientation
10 min
1:20 pm
Round 1 Small Group Discussion
Report Out
30 min
25 min
1:30 pm
2:00 pm
Break
15 min
2:25 pm
Round 2 Small Group Discussion
Report Out
20 min
15 min
2:40 pm
3:00 pm
Round 3 Small Group Discussion
Report Out
20 min
20 min
3:15 pm
3:35 pm
Discussion
40 min
4:05 pm
Public Comment
15 min
4:45 pm
Agenda Item
Duration
Time
Introduction
5 min
1:00 pm
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Thank you
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Attachment K. EPA Webinar Briefing Materials on Backhaul Alaska Program (1/30/2020)
The briefing materials used at the January 30, 2020 webinar for the EFAB on the Backhaul Alaska are
available on the EFAB web page, at:
https://www.epa.gov/waterfinancecenter/efab-webinar-backhaul-alaska
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Enclosure A.
Environmental Finance Advisory Board
Backhaul Alaska Consultation
Overview
On February 12, 2020, the Environmental Finance Advisory Board (EFAB) will engage in a consultation
with EPA on financing options for the Backhaul Alaska program. Prior to this consultation, the EFAB
prepared an advisory report in 2019 on revenue options for a waste service backhaul program in rural
Alaska, called Backhaul Alaska. At the request of EPA Region 10, the EFAB has agreed to engage in
further discussions on financing and governance options for the Backhaul Alaska program. A
consultation is a form of advisory activity that provides oral advice and feedback from the EFAB
members at a public meeting.
Product
The product of the Backhaul Alaska consultation will be a summary of the consultation discussions.
During the consultation, EPA seeks recommendations for the Backhaul Alaska program in each of the
following areas: (1) Structure, (2) Organization and Administration, and (3) Finance and Sustainability.
Session Framework
During the Backhaul Alaska consultation session, EFAB members will be presented with a scenario and
then the board will be broken into small groups to discuss tailored questions for each topic area.
Scenario:
The Backhaul Alaska program will be fully functional in March of 2021 (one year from now). It is
estimated that operations will cost approximately $1,000,000 per year to backhaul materials initially. At
full capacity, the program will cost about $3,700,000 per year. There will be an estimated $500,000
available for startup costs which will be funded through government grants. For the purpose of this
scenario, assume there will be an estimated $500,000 available for startup costs, funded through
government grants. Also assume that the first two years need to be funded via grants. Past that, the
ongoing funds will be a combination of (1) Government Funding (federal, state, tribal, or local grants or
appropriations), (2) Other funding, such as income from other Backhaul Alaska services (including EPR
support1), donations, and/or foundation grants, and (3) Program fees, collected from villages for
backhauling services. For purposes of this exercise, assume the below source funding ratio:
40% government
50% other funding and
10% program fees
Unless EFAB recommends differently, the organization will be set up as a non-profit with a Board of
Directors with advisory committees for each stakeholder group. Administration would be centralized
with possible contracting/sub-awarding of all or some program functions.
1 The Solid Waste Alaska Taskforce is pursuing a statewide Extended Producer Responsibility (EPR) initiative that will legislate
electronic manufacturer support of e-waste recycling. If successful, funding supplementation could be significant.
Page 1 of 3
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Task:
EFAB members are tasked with helping Backhaul Alaska partners design an organization that maximizes
the usefulness of each of the funding sources, is run efficiently within known legal constraints, and
leverages the opportunities inherent in having a multi-stakeholder funded organization.
Process:
EFAB members will be divided into three groups to each discuss one of the consultation's three focus
areas, using a set of structured questions. Each EFAB member will be assigned to a section to work on
for the first 30 minutes. After the first 30 minutes, each group will report out then EFAB members will
rotate to another group. One EFAB member will stay to be the "history". There will be a total of three
rotations so that all members have an opportunity to consider questions in all three topic areas.
Group report outs will answer the following questions:
1. What did you discuss?
2. What questions did you not get to?
3. What should the next rotation focus on first?
During the third and final group report out rotation, Groups will provide:
1. Summary of what was discussed by the group with recommended next steps
2. Recommendations for further information gathering.
3. Key take-aways especially related to opportunities or obstacles.
Group 1: Structure
A. Should Backhaul Alaska be organized as a not-for-profit or quasi-governmental authority (in the
latter case, with responsibilities delegated to it by the state)?
B. How do the structure and governance of Backhaul Alaska expand or limit alternative models for
long-term sustainability?
C. What not-for-profit (or hybrid) models might be appropriate for Backhaul Alaska and what
tradeoffs are involved?
D. What are the advantages/disadvantages of different corporate forms in funding Backhaul
Alaska? E.G. quasi-governmental, special districts, for profit, etc.
E. Should Backhaul Alaska be structured within or affiliated with an existing governmental or
nongovernmental organization in order to share capacities and improve effectiveness?
F. What other key issues should be addressed in this area?
Group 2: Organization and Administration
A. What technical and administrative capacities should Backhaul Alaska maintain internally, and
what functions might be contracted out?
B. How would an oversight board for Backhaul Alaska be organized to ensure stakeholder
representation as well as organizational accountability?
C. What external linkages will be critical for Backhaul Alaska and how can they be cultivated and
maintained overtime?
D. How would Backhaul Alaska communicate and interact with its stakeholders and constituents?
E. How should Backhaul Alaska prioritize its work and what challenges and risks are likely to arise?
F. How should Backhaul Alaska monitor and evaluate program performance?
G. What other key issues should be addressed in this area?
Page 2 of 3
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Group 3: Finance and Sustainability
A. How should capital expenses be funded by Backhaul Alaska, particularly startup expenses?
B. How should operational expenses be funded by Backhaul Alaska?
C. What combination of existing and innovative tax instruments, grants (governmental and
nongovernment), and fees should be used to support and sustain Backhaul Alaska, initially and
over time?
D. How should fee assessments in support of Backhaul Alaska be structured given locational and
resource disparities among villages?
E. Should Backhaul Alaska build an invested endowment fund in support of operations?
F. Can financial incentives for industry (positive or negative) be built into the Backhaul Alaska
program?
G. Can Backhaul Alaska transition from governmental support to be financially independent and
sustainable, and if so, how?
H. What other key issues should be addressed in this area?
Desired Outcome
EFAB will provide financial and organizational advice to help ensure that the Backhaul Alaska
organization is both fiscally sound and resilient to financial and other challenges.
Page 3 of 3
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Backhaul Alaska
Preliminary Cost Projections
for
Environmental Finance Advisory Board February 2020 Meeting
Comparison of Program Costs
Component
2020
2030
Program Operations
$ 785,825
$
1,136,169
Recycling, shipping
$ 51,107
$
557,869
Direct village investment
$ 181,752
$
1,673,716
Administration Indirect
$ 101,868
$
336,775
Total
$ 1,120,552
$ 3,704,529
Number of villages
17
162
Per village backhaul costs
$ 65,915
$
22,867
Per person backhaul costs
$ 218
$
66
Note: Program operations include state and regional coordination, training,
outreach. Village investment includes supplies, labor, O&M
Dollar Investment per Village
Component
2020
2030
Administration
$ 52,217
$
17,345
Recycling and Shipping
$ 3,006
$
3,444
Investment
$ 10,691
$
10,332
Note: At full program, the median village size is larger and more difficult
logistics (costlier) villages are added, so the recycle and shipping costs are
higher
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EPA Environmental Financial Advisory Board
February 11-13, 2020
Draft Proposed Charges for EFAB Discussion (as of 2/6/2020)
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DRAFT PROPOSED CHARGE FOR EFAB DISCUSSION
Stormwater Credit Trading 101: Advice for
Permit Writers and their Permittees
Problem Statement
As many cities in the United States continue to experience growth, the increase in stormwater runoff associated
with impermeable surfaces has presented challenges for many municipal water utilities trying to keep pace with
increasingly stringent Clean Water Act (CWA) permitting requirements.
To address these challenges, municipalities across the United States are implementing strict stormwater
management requirements for new and existing properties throughout their jurisdictions. These requirements
mandate a certain volume of stormwater be managed on those properties. The goal of these programs is to
reduce the volume of stormwater entering existing storm- and wastewater infrastructure, which improves
overall water quality at the point of discharge from municipal sewer systems.
While in some cases the costs of stormwater best management practices (BMPs) can be high, one of the key
obstacles facing building owners is the opportunity costs related to siting BMPs. For example, roof space for high
value amenities such as pools, bars, and decks, or underground space for parking can be limited if that same
space is used instead for BMPs. Further, the optimal location of a BMP from a watershed benefit standpoint
might not be where development is occurring. As such, cities and states throughout the country are exploring
the development of innovative market-based mechanisms that would allow private sector developers to finance
offsite projects with the sale of credits, which are used by property owners to meet their regulatory obligations
under new stormwater management standards. Similar to cap and trade markets for carbon dioxide emissions,
the advent of a credit against these standards creates a marketplace that drives competition and ultimately
provides the lowest-cost solutions to stormwater mitigation, thereby reducing costs of compliance.
EFAB Mission Fit
EFAB's mission is to explore ways to lower costs and increase investments in environmental protection.
Environmental markets are often designed to achieve both facets of this mission. Stormwater credit trading is a
new and exciting tool that CWA permittees might want to have at their disposal. With thoughtful market design,
it may be possible for those communities to drive low cost compliance, incentivize and increase economic
development by offering private developers an alternative compliance pathway, and drive investment in
environmental services to traditionally underserved/underinvested neighborhoods. EFAB may be able to provide
guidance and advice on how to structure these markets so that they can achieve these goals.
EPA Mission Fit
EPA's mission is to protect the environment through the enforcement of the nation's environmental regulations,
scientific research, and public education. Often this means working with communities to determine the best
pathways to achieve compliance in a cost-effective manner. In a February 6, 2019 memo1 Assistant
Administrator Ross reiterated EPA's support for market-based water quality programs, including water quality
trading and offsets, and encouraged regional offices to find opportunities to promote market-based programs
within its regulatory mandates.
Type of EFAB Engagement
EFAB could assist EPA through a written report that would provide guidance to permit writers and their
permittees on how to implement stormwater credit trading. This may include market design, incentives design,
market administration, among others.
1 https://www.epa,gov/sites/production/files/2019~02/documents/trading-policy-memo-2019, pdf
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DRAFT PROPOSED CHARGE FOR EFAB DISCUSSION
Environmental Finance Advisory Board
Addressing Affordability Challenges to Equitable Water Service Delivery
As water service rates have risen faster than inflation and income growth, addressing water affordability has
become a central policy issue. This focus has prompted a number of studies and research efforts that offer
alternative measures of household burdens, delineate geographical distributions of water service cost
burdens, and outline potential revisions to methods for assessing community financial capabilities (including
EPA's ongoing review of its 1997 methodology guidance).
In the last two decades, EFAB has developed two related charges that addressed: (1) potential rate design (and
complimentary customer account management) options to address water affordability,1 and (2) how the EPA's
Water Infrastructure and Resiliency Center could assist local governments with affordability challenges.2 In
subsequent years, particularly after the Flint Water Crisis and various reports on water access challenges In the
United States,3 the water service sector is redefining its services in terms that challenge historical pricing
through measures of billable volumes and customer account management practices. This more explicit
recognition of the importance of water affordability to fulfill the water sector's public health protection
responsibilities has complementary implications for regulatory, financial, and technical support initiatives.
Problem/Question Statement
This proposed EFAB charge is to develop recommendations for how EPA's enforcement practices and financial
and technical assistance programs may be modified to enhance and amplify the ongoing refinement of water
service definitions that highlight the importance of assuring water affordability and access. These refinements
recognize that water services are more than management of drops measured through water meters and
impervious area measures. They more explicitly recognize the public health protection value conveyed, and
the attendant imperatives to assure access and affordability. The charge is to address how EPA can help ensure
that the costs of compliance with environmental regulations do not impose inequitable burdens on
economically disadvantaged households while also advancing water quality improvement and utility system
reinvestment. The charge is to gauge the extent to which EPA-sponsored financial and technical assistance
programs may be modified to address community access and affordability challenges to render more equitable
outcomes.
EFAB Mission Fit
The charge is oriented toward providing recommendations related to EPA's approaches to enforcement of
environmental regulations that may have acute impacts on community financial capabilities and household
affordability, and on how EPA could modify its financial and technical assistance programs to enhance support
to communities with affordability and access challenges.
EPA Mission Fit
The proposed charge is intended to provide recommendations primarily to enhance existing EPA programs and
practices established to serve EPA's mission.
Type of EFAB Engagement
• EFAB workgroup written report
• EFAB-sponsored workshop
1 Affordable Rate Design for Households, EFAB report dated February 2006.
2 Household Affordability Challenges in the Water Sector, EFAB report submitted February 26, 2016.
3 Closing the Water Access Gap in the United States: A National Action Plan, Dig Deep and US Water Alliance, 2019.
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DRAFT PROPOSED CHARGE FOR EFAB DISCUSSION
Risky Environmental Business: Impact on Cost of Capital for Utilities
EFAB members: J. Beecher, T. Chapman, E. Crooks, R. Weiss
Problem/Question Statement
Capital and insurance markets are increasingly recognizing environmental factors in their assessment of
risk profiles and credit quality. The relevant risks factors are also expanding in the context of complex
systems encompassing both the natural and built environments. Risk relates to interrelated aspects of
utility operations, including reliability, resilience and regulatory compliance. In addition, there is growing
recognition that environmental risks, including those associated with natural or humanmade disasters,
are affecting the cost of capital. Managing and mitigating risk is a priority of utility managers.
Environmental, resource, and economic regulators are increasingly risk aware.
The following key questions are of interest:
What risk factors (including environmental risks) are affecting utilities and how are they being
addressed? Examples of risk impacts include cost (increased capital or operations scope,
reporting and administrative effort, etc.), schedule (delays due to required environmental
permits/approvals), and increased uncertainty about project viability (affecting cost of capital
and increasing contingencies).
How can utilities more effectively manage risk, and which tools are most cost-effective for which
risks?
Which categories of risk have been the most challenging for utilities to manage effectively, and
why?
How are utility credit ratings and insurance products affected by risk?
How is changing risk affecting utility capital costs and revenue requirements?
How does utility ownership affect risk management?
For the private sector, how are risks shifted between shareholders and ratepayers?
How does risk-bearing relate to issues of environmental justice?
What practices and products can utilities use to manage or mitigate risk?
How are various types of risks disclosed and reported?
What tools are available for evaluating risk, including scorecards?
EFAB Mission Fit. Risk is a natural topic for the EFAB due to its implications for the financial health and
viability of utilities. EFAB members have considerable expertise in how financial markets perceive and
process risk, and how this in turn affects utilities.
EPA Mission Fit. EPA's interest in risk relates its roles as the nation's environmental health regulator but
also as a source of capital financing. Better risk management has implications for the financial health of
utilities and thus public health over the long term.
Type of EFAB engagement. We recommend an EFAB consultation at a public meeting or an EFAB-
sponsored educational workshop with a written summary. We view this topic as an opportunity to share
knowledge about financial risk and its implications with stakeholders in the environmental policy
community.
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DRAFT PROPOSED CHARGE FOR EFAB DISCUSSION
Attracting Private Investment to Opportunity Zones: A Role for EPA
EPA Efforts in Opportunity Zones
In December 2018, the White House Opportunity and Revitalization Council (WHORC) was
established by Executive Order 13853 to implement administrative reforms and initiatives to
target, streamline, and coordinate Federal resources in economically distressed communities.
EPA is a member of the Council and is included in two separate work streams: Safe
Neighborhoods and Economic Development. In addition to tax incentives for development in
designated Opportunity Zones (OZ) provided by the Tax Cuts and Jobs Act of 2017, a new
feature on grants.gov beginning in March 2020 will enable applicants to search for available
grants/programs across the federal government that benefit OZs. This will benefit OZ
stakeholders by increasing general awareness of federal programs with OZ benefits.
Problem/Question Statement: Maximizing the Impact of EPA Investment in Distressed
Communities
The OZ initiative creates incentives for equity investments in real estate and infrastructure
projects as well as new or expanded businesses located in the designated OZs. It is principally
an economic development initiative that is designed to support the revitalization of
communities to address chronic and acute problems that result from economic decline. Many
of these problems relate to the environment and human health.
Our experience with community-focused programs suggests that economic investments from
the private sector are far more likely and attractive when environmental quality is maintained
at healthy levels. Potential environmental liability and uncertainty about environmental quality
can also discourage private sector investment in a community. We believe that additional
environmental infrastructure and improvement is a necessary condition for attractive private
sector investment in many communities, even with OZ incentives.
Investing in distressed communities is not new for EPA. The agency has historically provided
support to communities through mechanisms that have included grants, tools, training,
education, and technical assistance. Despite these efforts and investments, EPA cannot always
determine, in advance, whether its limited resources will be effectively leveraged to make a
measurable environmental and public health improvement for these communities.
The EPA would appreciate any strategic advice from the EFAB on ways to encourage private
investment in OZs. Specific questions include:
1) First, which specific federal/EPA incentives (monetary or otherwise) are most likely to
increase public/private investment in OZs?
2) Looking at existing EPA incentives, including funding programs such as environmental
justice, or brownfields grants which incentives, programs or approaches are better
suited to achieve desired community outcomes while reducing risk, liability and/or
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DRAFT PROPOSED CHARGE FOR EFAB DISCUSSION
regulatory uncertainty for investors in OZs?
3) Does the EFAB have recommendations on readily implementable adjustments to
existing Agency programs to make them more effective in reducing risk, liability and/or
regulatory uncertainty? Are there more complicated adjustments that should be also
considered by the Agency?
4) What regulatory/liability/risk data could be provided to allow investors to compare OZs
and determine which OZ might be a best fit for their investment?
5) Does the EFAB have any recommendations on how we share information and resources
in a way that would ensure that the programmatic resources we leverage for OZ
purposes lead to improvements in local health and environmental outcomes for the
existing community.
EPA Mission Fit:
The EPA Office of Policy (OP), located in the Office of the Administrator, is the primary policy
arm of EPA. Among other duties, OP is responsible for coordinating all of EPA's Opportunity
Zone (OZ) work across the agency. OP has extensive experience in working in economically
distressed communities across the country to support locally led, community-driven strategies
that improve economic development and environmental and human health outcomes. OP uses
this expertise in coordinating across EPA programs and in collaboration with other federal
agencies to assist communities' efforts to ensure that public and private sector investments
support community goals.
Type of EFAB Engagement: to be determined
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