WATER

INFRASTRUCTURE

FINANCE AUTHORITY
OF ARIZONA

*>EPA

Clean Water

State Revolving Fund

United States
Environmental Protection
Agency

Supporting Wildfire Resiliency
Using the CWSRF Program

An Arizona CWSRF Nonpoint Source Pilot







December 2024

EPA 841-R-24-011


-------
Addressing a Growing Problem

Arizona recently used the Clean Water State
Revolving Fund, or CWSRF, to help its citizens
better protect their communities from wildfire. The
United States has averaged 70,000 wildfires per
year since 1983. The wildfire season is lengthening
in many areas due to warmerspringtemperatures,
decreases in precipitation and snowpack, longer
dry spells and drier soils and vegetation. As global
temperatures have increased, the size and severity
of wildfires have increased. Although the entire
United States is affected by wildfire, National
Interagency Fire Center data show the western
United States has been the most impacted region.

Wildfire can be a significant source of water quality
impairment because the loss of vegetation and
subsequent erosion from barren slopes can lead to
flash flooding, excessive sedimentation, degraded
water supplies and diminished recreational
opportunities.

Arizona has a long history of devastating wildfires
that have burned millions of acres, and these
have become more frequent and devastating over
the past 20 years. Communities have seen their
homes and businesses destroyed, drinking water supply resources damaged and forests decimated.
Arizona now experiences an average of 1,500 wildfires every year — more details are available in the
2023 Wildland Fire Annual Report. That trend seems likely to continue, as research indicates that the
southwest United States is experiencing an ongoing megadrought.

The Water Infrastructure Finance Authority of Arizona, or WIFA, which administers the CWSRF in
Arizona, has been promoting the CWSRF program for projects that address watershed health, green
infrastructure and nonpoint source water quality challenges for many years. WIFA coordinates with
its sister agency, the Arizona Department of Environmental Quality's Clean Water Act Section 319
Nonpoint Source Program, to identify critical needs and opportunities for project funding. In 2019,
WIFA signed a $6 million CWSRF loan with the city of Flagstaff to help finance the activities of the
Flagstaff Watershed Protection Project, which is a partnership effort between the city of Flagstaff, the
State of Arizona and the Coconino National Forest to implement forest thinning, prescribed fire and
other treatments aimed at reducing the risk of severe fire behavior and post-fire flood effects.

Smoke from the June 2010 Schultz Fire sweeps
over the ridge of the Vulcan Mine in the Coconino
National Forest, Arizona.

2


-------
What Are the Negative Impacts of Wildfire?

•	Drinking water resources and treatment cost increases: Impacts on drinking water
supplies can persist for at least 5 - 10 years post-wildfire. Negative impacts include increased
sedimentation and turbidity, spikes in nonorganic matter and changes in pH and alkalinity
that may require changes in treatment methods, cause increased treatment costs and
prompt a need to find new water sources, either temporary or permanent.

•	Utilities and infrastructure damage: Wildfires can quickly destroy/disrupt critical
communication and utility assets, such as communication towers and electrical transmission
lines, which can be disastrous for firefighting efforts, emergency response, personal
communications and business operations during and afterthe wildfire. Fully replacing or
restoring the lost or damaged infrastructure can take years.

•	Property loss: Wildfires can destroy homes in the wildland-urban interface, and the
aftermath can significantly impact the value of the remaining homes left intact nearthe
burned areas.

•	Recreational value and job losses: Outdoor recreation is an $11 billion industry in Arizona.
Wildfires have closed recreational facilities for months, sometimes years. Such closures can
result in the loss of thousands of local jobs and millions of dollars in income and revenue.

•	Critical habitat loss: The loss of forests and vegetation can destroy or damage wildlife
habitat for important species, such as the endangered Mexican Spotted Owl.

•	Health and economic prosperity declines: Many impacts that hit communities hardest
come afterthe fire. Injuries, cardiovascular illness from smoke inhalation, emotional trauma
and mental health treatment result in physical and financial costs to individuals.

In 2019 WIFA requested assistance through a U.S. Environmental Protection Agency CWSRF Nonpoint
Source Pilot Program to identify tools and strategies for expanding CWSRF financing for wildfire
resiliency and to create a CWSRF Forest Thinning and Restoration Program. WIFA sought advice on
the following issues:

•	What is the most effective way to finance wildfire resiliency projects with the CWSRF,
particularly when much of the work will occur on federal or private land?

•	How can WIFA make communities more aware of the availability of CWSRF financing for forest
restoration projects to generate interest and demand?

•	Can WIFA play a role in increasing investment in wildfire resiliency statewide to reduce the
impacts of catastrophic wildfires?

•	What is the potential demand for CWSRF financing, and what are the options for repayment?

3


-------
Obtaining Critical Funding for Wildfire Resiliency

CWSRF federal eligibilities allow forthe financing of nonpoint source projects if they implement
the state's Section 319 Nonpoint Source Management Plan. Arizona's Section 319 plan specifically
identifies wildfires as a source of water quality impairment. Although the federal CWSRF statutes
allow nonpoint source financing to go to either public or private borrowers, Arizona's CWSRF
program statutes only permit loans to public subdivisions of government, such as counties, cities,
towns, special taxing districts and Tribal authorities (see Arizona Revised Statutes Title 49, Sections
1203(B)(1)(b) and 1201(14)). Notwithstanding this statutory limitation, WIFA recognized that public
entities are not the only ones implementing forest treatments, so it had to plan for innovative options
for financing forestry projects.

Many states, such as Arizona, face hurdles because lending is limited to municipal entities. Pass-
through loans are commonly used by these CWSRF programs nationally to fund nonpoint source
projects by taking advantage of existing relationships with public borrowers. This structure allows
a municipality to act as a conduit through which CWSRF funding can pass through to watershed
partners who can implement the project. These watershed partners are responsible for repaying the
loan proceeds to the conduit municipality, which in turn repays the CWSRF program (Figure 1).

The pass-through loan mechanism
allows state CWSRF programs to
broaden the horizon of eligible projects
and the types of borrowers to which
they may offer loans. For WIFA, one
of the most attractive features of this
approach is that the loan forgiveness
it planned to allocate to CWSRF loans
for forest treatments could be passed
along to the watershed partnership
borrower(s). Due to these benefits,
WIFA determined that pass-through
would be the most likely way it would
offer financing to future CWSRF Forest
Thinning and Restoration Program
projects.

Pass-Through Lending

The CWSRF makes
a Loan to a public
entity.

The public entity
makes smaller
loans to nonprofits,
watershed groups
private entities to
implement forest
thinning work.

Clean Water

State Revolving Fund

Eligible
Public
Borrower

The entities
implementing the
project repay the
public entity using
sources like tax
revenue, license
fees, dues or other
grant funding.

The public entity
uses the proceeds
to repay its loan to
the CWSRF.

ooo

Figure 1. CWSRF's pass-through lending process.

4


-------
Meeting the Funding Need

The CWSRF can play a key role in providing "gap" financing for forest treatments. The U.S. Forest
Service's budgets for treatments such as thinning and prescribed burns to prevent or mitigate
wildfire risk are insufficient to cover the full need. Although Forest Service budgets forfuel
management activities have increased in recent years, the need greatly surpasses the appropriations,
leaving the Forest Service and communities to pursue additional options to help finance the work.
For instance, the Forest Service is paying for half of the $62 million in thinning activities around
Arizona's C.C. Cragin Reservoir, which supplies drinking water to residents in Phoenix, Payson and
other areas. The remaining funding is coming from utilities and ratepayers. There is an opportunity
for the CWSRF to supplement Forest Service funding at a low cost to cover this gap. This situation is
similar elsewhere in Arizona and thus represents a significant opportunity for WIFA to contribute to
making communities and water resources safer.

To the extent that equipment is needed to implement a state's nonpoint source management
program plan, the CWSRF can also finance needs such as environmentally friendly logging
equipment. CWSRF could also potentially support technology like air curtain burners, which can
transform biomass from excess fuel loads into biochar, a versatile product that can enhance pollutant
removal when incorporated into green stormwater infrastructure practices.

Identifying Repayment Sources

The range of repayment options for a CWSRF loan is broad. CWSRF-funded forest restoration projects
are no exception. Although forest treatment projects can be partially paid for by using timber and
biomass revenues, the Flagstaff team acknowledged that these sources might offset the cost only a
little. Borrowers have used a wide range of options to repay loans for nonpoint source projects. These
options are discussed extensively in the EPA report, Financing Options for Nontraditional Eligibilities in
the Clean Water State Revolving Fund Programs. A few repayment options are highlighted below:

•	Tax pledge - A pledge of tax receipts, such as property taxes, flood control taxes and sales taxes.
The CWSRF loan awarded to the Flagstaff Watershed Protection Project used a tax pledge.

•	Water utility revenue pledge - Water treatment costs can increase substantially in the months
and years following a wildfire. Water utilities in Denver, Santa Fe and Little Rock have used fees
on water bills to fund forest restoration projects. Flagstaff has also approved a monthly fee on
water bills to pay for ongoing maintenance and investments in forest restoration.

•	Timber revenues - At least half of the material obtained in forest thinning is usable lumber.
Although transportation costs can be high, there may be revenue potential for loan repayment.

•	Revenues from lower-value slash - Entrepreneurs and government agencies are exploring
potential uses for the lower-value biomass removed during forest thinning; biochar, for

5


-------
example, can be used as a soil amendment to improve water and fertilizer retention, increase
soil carbon and trap pollutants.

•	Electricity generation - Biomass collected during forest thinning could provide fuel for
electricity generation. In California, Phoenix Energy has co-located small biomass gasification
plants at the sites of biomass collection, powering nearby facilities while also creating biochar.

•	Fees on park concessions - Recreation activities and lodging generate significant revenues in
national forests, mainly through concessions. A small percentage fee added to a bill could be a
source of income for repaying loans that benefit the forest area.

Although the revenue potential for timber revenues, including from slash, and electricity generation
is currently low, research and investments aim to expand these options. At this time, these potential
revenue sources may not be sufficient to ensure full repayment of a CWSRF loan, so additional
sources of security, such as taxes and utility revenues, may be needed to take on a loan. This list
of repayment options is not exhaustive. The EPA report mentioned above describes other options,
including foundation support, corporate sponsorship, nonprofit fees, development impact fees and
nutrient and carbon trading.

Communicating Project Benefits

Obtaining public buy-in for forest treatments is essential in any state, and communication is key.
In Arizona, law requires that communities larger than 150,000 people must obtain approval for a
WIFA loan by a referendum (for more details, see Arizona Revised Statutes Title 9. Section 571(C)).
Municipalities bound by this requirement include Phoenix and many of its surrounding communities,
even as their locations in the Salt River and Upper Gila River watersheds put them at risk from
wildfires in the surrounding national forests. A 2018 survey and a 2019 focus group of potential
WIFA borrowers confirmed that the referendum requirement significantly impedes participation.
Therefore, ensuring that communities learn and understand the project benefits will help bolster
their support during elections to approve funds for forest treatment projects.

Some Arizona cities, faced with mounting wildfire threats and damage, are making progress on
improving communication efforts. For example, during the two years after the city of Flagstaff was
impacted by the effects of a catastrophic 2010 wildfire, the city conducted a coordinated campaign
focusing on the avoided costs of investing in forest treatments (see box, next page). As a result, the
city sought and obtained overwhelming approval for a $10 million bond measure in 2012.

Given Flagstaff's successful efforts to gain approval forforest thinning projects by demonstrating
the avoided costs, WIFA focused its marketing efforts for the CWSRF Forest Thinning and Restoration
Program on the measurable benefits of prospective projects. To identify specific, measurable
benefits, WIFA created a Measurable Benefits Tool, which can be used to calculate the environmental,

6


-------
Case Study: Flagstaff Watershed Protection Project

In 2010, the city of Flagstaff was ravaged by the
Schultz Fire, which consumed more than 15,000
acres of forest outside the city and caused nearly
$147 million in damage and the loss of one life
in post-fire flooding. The city used the results of
Northern Arizona University's full cost accounting
study of the fire and the strong and vocal backing
of the city's fire department to educate local and
regional stakeholders on the importance of taking
preventative measures through forest thinning and
restoration. This led to a ballot initiative in 2012
for a $10 million bond election framed as a critical
measure for protecting drinking water supplies
and water infrastructure.



The educational campaign was a success, with	X /A

an overwhelming 74% of the Flagstaff voting	|pr	_J||. jf

public approving the $10 million bond measure.

The initiative, now known as the Flagstaff	I

Watershed Protection Project, was the first time

the city considered nonpoint source projects to t|C|EB|0EB

be a part of their Capital Improvement Program

and included them in their water infrastructure

budget. It is also the only known project of its kind

in the country where forest restoration work in a national forest has been funded
municipality. The 2019 CWSRF loan is part of this bond measure.

• 1





-v

economic and social costs and benefits of investments in fuel treatments that can help avoid
catastrophic wildfires. The objective of the Measurable Benefits Tool was two-fold:

•	Provide real, actionable data for potential municipal and Tribal borrowers on the investment
and the potential benefits of borrowing through the CWSRF.

•	Offer data and tools to prospective borrowers so they can gain approval from their leadership
and voters, if necessary.

The Measurable Benefits Tool developed for Arizona underthis pilot project uses quantifiable
metrics designed to communicate values that everyday citizens can readily relate to. These data are
important to help gain approval for projects from community leaders, as well as voters, if necessary.
The metrics in the tool include:

• Lost revenues to local economies


-------
•	Impacts on real estate and property values

•	Avoided drinking water treatment costs

•	Impacts on recreation and tourism

•	Public health and economic prosperity

Although these measures are not exhaustive, they provide a well-rounded picture of the potential
benefits of forest restoration using available data sources. While a significant portion of the response
and suppression costs is typically borne by the federal government, the remaining costs directly
impact the local economy, employment and tax revenues.

The Measurable Benefits Tool is customizable by city, county or national forest entities. This
customization allows WIFA to create marketing and education packages tailored to the location and
characteristics of the community and
stakeholders. EPA's contractor used the
outputs from the Measurable Benefits
Tool to develop a full suite of fact sheets
to accompany each metric, which
may be distributed electronically or
printed for handing out at conferences,
workshops and community meetings.

They are suitable for use by WIFA and
stakeholders interested in pursuing
forest thinning and vegetative
management efforts in their own
communities and watersheds across
Arizona (Figure 2).

To help launch the program, WIFA also
developed a trifold brochure to highlight
the Flagstaff loan, the cost savings that
can be realized from investing in forest
restoration and the importance and
benefits of undertaking such projects,
it also describes the Arizona CWSRF
program, its financial offerings and
its continued commitment to serving
Arizona communities and their water
quality needs (Figure 3).



How do wildfires

impact our
infrastructure?

Wildfire Damage to

Utilities & Infrastructure

Drinking Water Supply

Post-fire runoff can pollute reservoirs
with debris and chemicals, rendering

the water supply unusable

€

Treatment & Distribution

Up to $37 million to restore local
drinking water infrastructure from
post-fire runoff

G

Emergency Response

Disruptions to critical communication
infrastructure impacts first
responders.



The Value of Utilities
$84-224 million in

communications assets on two
vulnerable mountains.

Many communication towers are located
on mountaintops, making them vulnerable
to wildfire. Arizona's Mormon Mountain
and Mount Elden each host numerous
communication facilities used by:

County Law Enforcement
Cellular Phone Service
Providers

Internet Providers
Telephone Providers

Television Stations
FM radio broadcasters

A fire would disrupt or destroy
communications such as cell phone
service, Internet, radio, and public
safety including law enforcement,
fire and emergency medical services.
The impact would be disastrous for
personal communications, business
operations and fire suppression efforts.

I

WIFA's Forest Thinning &
Fire Prevention Program

WATER
! INFRASTRUCTURE

FINANCE AUTHORITY
OF ARIZONA

Figure 2. Example utilities fact sheet developed from the
Measurable Benefits Tool's outputs.

8


-------
YOU BENEFIT FROM
MORE THAN JUST

BELOW-MARKET
INTEREST RATES

yf INTEREST RATE SAVING UP TO 3D PERCENT
yj UP TO ZO PERCENT LOAN FORGIVENESS
\f 30-YEAR REPAYMENT TERM

\f FUNDING FOR SMALL AND LARGE PROJECTS
\f YEAR-ROUND APPLICATIONS

NO APPLICATION FEES OR CLOSING COSTS

/ MOST PROJECTS EXEMPT FROM RE
V QUIREMENTS (DAVIS-BACON WAGE RATES
AND AMERICAN IRON AND STEEL]

\f PLANNING GRANTS MAY BE AVAILABLE

yj PERSONAL SERVICE 6 DEDICATED PROJECT
MANAGER

FINANCING FOREST RESTORATION PROJECTS
CAN BE CHALLENGING.
WITHWIFA.IT DOESN'T HAVE TO BE.

Have a viable project but not on this list? WIFA can fund projects on state
and federal forestland, as long as the project is sponsored by an eligible
jurisdiction. Contact us to discuss your options.

FOREST THINNING &
RESTORATION PROGRAM

Below-market loans for your forest
restoration projects.

PUBLIC JURISDICTIONS & TRIBAL ENTITIES ARE ELIGIBLE

•	Cities

•	Towns

•	Special districts

•	County improvement districts

•	Sanitary districts

•	Native American Tribes & Tribal Authorities

OF ARIZONA

100 N. 7th Avenue, Suite 130/Phoenix, AZ 85007
Phone:(602)364-1310 • E-mail:! iones@azwifa.aov

M WATER INFRASTRUCTURE

S=gj FINANCE AUTHORITY OF ARIZONA

WIFA IS THE PREMIER
WATER QUALITY
FINANCING AGENCY
IN ARIZONA

Forest fires can cause millions of dollars in firefighting
costs and devastating damage to homes, businesses,
ecosystems, and water quality. A below-market loan
from WIFA can help your community avoid these costs
by accelerating forest restoration projects, including
forest thinning, tree planting, and stream restoration.

FLAGSTAFF SAVES
20% FINANCING
WITH WIFA

In 2019, the City of Flagstaff signed a $6 million WIFA loan,
including $1 million in loan forgiveness, to support the
Flagstaff Watershed Protection Project (FWPP). Funding will
help reduce the risk of wildfire and post-wildfire flooding
in key watersheds through restoration projects in Coconino
National Forest.

THE CITY SAVED MORE THAN

$1.7 MILLION

BY FINflCING ITS PROJECT WITH WIFA

HEALTHY FORESTS REDUCE WATER
TREATMENT COSTS!

SAVE MONEY, PROTECT YOUR ASSETS

A $10 million loan from WIFA could help prevent $25 - 51 million in
wildfire suppression and rehabilitation cost plus millions more in prop-
erty losses, lost recreational values, and additional water treatment costs.

FOREST THINNING MAKES SENSE

Theaftermathofwildfirescanbedevastatingtowaterquality,withflooding,
mudslides,erosion,and wastesedimentstrainingwatertreatmentfacilities.

INVEST IN ARIZONA

YOUR REPAYMENTS STAY IN ARIZONA FOR FUNDING FUTURE
PROJECTS!

^ A O

CONTACT US WITH YOUR PROJECT IDEA!

The Water Infrastructure Finance Authority is dedicated
to maintaining and improving water quality for all Arizo-
nans. We provide financial and technical assistance for
water quality and drinking water projects throughout the
state. Forest restoration is just one of many eligible pro-
ject types, from traditional infrastructure to innovative
nonpoint source solutions to water quality impairment.

Since 1998, WIFA
re-invested almost

in Arizona
communities

Figure 3. WIFA's trifold brochure explains the program's economic and environmental benefits.

9


-------
Sharing Lessons Learned

This pilot project is the first time a CWSRF program has worked to develop a program specifically
aimed at forest treatment and wildfire resiliency. Lessons learned include:

•	Critical partnerships - CWSRF financing typically requires collaboration between the program,
the borrower and their contractors. In forest restoration, CWSRF participation may require
working with a wider range of entities, including the Forest Service, local governments, Tribal
entities and citizen groups. The city of Flagstaff's success can be attributed to its investments

in developing partnerships, obtaining buy-in from citizens and committing to maximizing other
funding sources, such as grants and in-kind support. The former Flagstaff Watershed Protection
Project manager, who had been previously unaware of WIFA or the CWSRF, gives credit to "Team
Flagstaff" for the loan, as other city staff helped the project team reach out beyond their typical
contacts to identify more creative financing opportunities.

•	Strategic engagement and messaging - Successful forest treatment programs have framed
their work as an investment in avoided costs to prevent catastrophic wildfires. Several cost-
avoidance studies, including the Flagstaff Watershed Protection Project's, have shown that the
costs of recovering from wildfire significantly outweigh the costs of forest treatments to reduce
the risks of catastrophic fire. Obtaining public support forthe investments by clearly showing
the costs avoided was a key factor to success in Flagstaff and other western cities, such as Santa
Fe and Denver. The Measurable Benefits Tool created in this pilot project supports strategic
engagement and messaging because it is designed to help calculate the potential avoided costs
and convey the messages in a way that is approachable and easily understood by all citizens.

•	Replicability - The likelihood of higher-intensity wildfires that burn larger areas has grown
over the past two decades, with western states at increased risk. The Forest Service has been
characterizing watersheds at higher risk to aid in prioritizing restoration efforts, using tools such
as Forests to Faucets and Wildfire Risk to Communities. Third-party watershed organizations in
states throughout the western U.S. play a significant role in securing financing and coordinating
projects to implement forest restoration activities to limit catastrophic wildfires. With a need
forfunding in each of these at-risk watersheds, CWSRF programs can play an important role.

As the nation's largest low-cost source of waterquality financing, it can help ensure necessary
projects are completed more quickly and on a largerscale. The use of the Measurable Benefits
Tool orsimilar approaches in states prone to catastrophic wildfires can help communities and
watershed groups make the case for investing in forest restoration efforts and the use of the
CWSRF to help finance those investments.

10


-------