Frequently Asked Questions

Are there ongoing efforts in my state to comment on State Revolving Fund policy and Intended Use Plans that I can plug into or lead?

Check out our advocacy engagement tracker to see where Forum participants are submitting comments. The SRF Advocates Forum can offer support for your leadership on SRF policy analysis and advocacy in your home state.

How can I make other advocates aware of my efforts so they may join or contribute?

Tell us about your advocacy so that we can elevate your effort to other Forum participants. Feel free to use the resources on the Forum website to help educate your partners and share this advocacy opportunity with coalitions in your state.

How can advocates learn about SRF Intended Use Plans (IUPs) and priority projects allocated funding in my state(s) of interest?

Federal law requires intended use plans (IUPs) to be made public with a comment period (states often follow a practice of 21-30 days). However, there is variation among states in how easy IUPs are to find and the accessibility of the engagement process. Some states have the practice of – in addition to official IUPs – publishing public comments received and the state’s responses (e.g., Wisconsin, California, and Ohio). Advocates may consider offering those states as examples of best practices to your home state through public comments and other advocacy efforts.

Procedural justice and data transparency are nationally pervasive issues, and Forum Advocates have shared lessons learned from their experiences with state-level advocacy for inclusive and transparent IUP processes. For example, in addition to engaging with state agencies through IUP comments, advocates have submitted FOIA (Freedom of Information Act1) public information requests. Other Forum members and partners have done deeper dives into the need for and possible approaches for states to better center procedural justice in IUP processes in reports and recommendations available online. While official assessments of funding allocations tend to come later through EPA’s data system (DW and CW), in the meantime, you can explore EPIC’s dashboard, which tracks the flow of SRF funds.

Where can I learn more about procedural justice?

The Spectrum of Community Engagement to Ownership is a good resource.

Projects in my jurisdiction are not scoring high enough in project priority lists, even after repeated proposals. Are we doing something wrong?

Most state SRF programs are overprescribed, receiving significantly more proposals than they can fund with existing resources. This means many deserving projects will be left off funded priority project lists. Technical assistance (TA) providers, like EPIC, can help project proponents meet readiness-to-proceed requirements including environmental assessments, engineering reports, etc., which can affect a project’s scoring. Explore technical assistance opportunities offered by the US EPA to learn more. EPA also recently rolled out additional avenues for TA support that might be a good fit for your jurisdiction to explore. Even if utilities have already submitted unsuccessful project proposals, TA could help identify project proposal improvements for subsequent consideration in future IUPs.

How else can advocates engage SRF besides submitting public comments on IUPs?

Forum partners firmly believe in the success of proactive relationship building with SRF state admins within and outside of public comment periods on IUPs. You don’t have to wait until the public comment period to reach out and connect with your state’s SRF admins. Additionally, if advocates work with utilities submitting projects or community-based organizations (CBOs) assisting community engagement on project development, Forum partners have found success in some states starting with the TA process and engaging at least a year prior to project submittal.

Can state SRF administering agencies update definitions (e.g., Disadvantaged Communities; Affordability Criteria) and procedures without legislative changes?

The underpinnings and primary lawmaking guiding disbursement of funds is driven by the Safe Drinking Water Act and amendments to the Clean Water Act, for DW SRF and CW SRF programs, respectively. Although federal rules govern funding allocations for the programs, Forum partners believe that state agencies have broad discretion to set priorities for project funding allocated to their state. How states leverage that authority varies from state to state. In some instances, there is no explicit limiting statute governing SRF administration by the assigned state agency – allowing the agency to exercise greater discretion (e.g., Illinois). In contrast, the Michigan state legislature placed limits on the frequency of updates to DAC definitions to once every three years and set parameters for how the administering state agency can define DACs. To learn more about your state’s SRF program, River Network has compiled a list of state agencies administering SRF programs, and EPA Regional Offices.

How are definitions of Disadvantage communities (DAC) changing across the nation?

The US EPA has tracked some changes, see a 2022 Reference Guide on DAC definitions for Drinking Water SRF. The Association of State Drinking Water Administrators produced a helpful white paper on DAC definitions.

 My understanding is that Bipartisan Infrastructure Law (BIL) funds cannot be used for partial lead service line replacement projects, is that true?

Yes. The federal law (BIL) is explicit – BIL funds cannot support partial lead service line replacement projects. States may or may not articulate that detail in their IUPs, but it still applies.

What is a partial lead service line replacement?

This involves a project in which states replace the public side of a service line only. In other words, sections within private property are not replaced, even if they are “the same” service line. This leaves lead lines in place on the private side of the water service and will not fully remediate potential lead exposure.

When dollars are repaid or revolve back into the state’s revolving fund, are those dollars still federal dollars? When do they become “state dollars”?

The federal government provides capitalization grants to states to operationalize their SRF program. In other words, the money is for the states to loan out, though certain requirements may apply for the initial infusion. States have more liberty with repaid SRF loans. For example, supply chain requirements (e.g., Build America, Buy America), only apply to the initial capitalization grant from the federal government, they do not apply to the revolving repayments in future years.

How can states leverage SRF bonds?

We encourage states to leverage SRF bonds. In practice, these are bonds issued against future SRF loan repayments. Such bonds increase the pool of available funds for water projects. Here is a helpful overview of leveraging SRF appropriations.

Can states use BIL funds to increase staff capacity?

States can use up to four percent of their federal capitalization grant for program administration. Funding can be sourced from BIL supplemental grants as well as base grants. Therefore, BIL substantially increases available funds to build the capacity of state staff.

The SRF program is complicated, and my organization is just getting started in advocacy for our communities; does the Forum offer additional support to those who are just entering this space?

YES! Check out River Network’s self-paced training series which includes presentations from Forum partners and other SRF experts. You can also explore a set of fact-sheets on the SRF Advocate Forum website which also houses recordings of Forum convenings. Forum members are also great thought partners and often share experiences and resources on the Forum Mobilize site – we encourage advocates to sign up to participate in the Forum to receive notifications of shared content.

Is there someone that can help me understand how to leverage SRF to secure dignified, good-paying jobs for my community?

Connect with Richard Diaz (rdiaz@bluegreenalliance.org) for inquiries on workforce development. You can also learn more about workforce development mechanisms in the SRF Advocacy Toolkit’s Workforce Development Section. 

When are SRF applications typically due?

SRF application deadlines vary by state. Additionally, there isn’t a national database for this information. River Network is working towards crowdsourcing relevant SRF application details on their website. Forum members and other advocates are encouraged to check their state SRF administrator’s website, look at dates of prior IUP releases and open calls for projects/notice of interest/intent to apply, and sign up for any relevant state listservs.

In our state, advocates are interested in ways to bridge the needs of rural and urban communities. We find that DAC definitions often discount one or the other. How have others approached this?

The Forum has explored a point system in the definitions of disadvantaged communities. In other words, rather than states using an in-or-out criteria, we instead endorse the use of a scaled DAC definition with multiple factors that can relate to challenges experienced by rural and urban communities. Having a scaled DAC definition would help SRF admins understand who to prioritize for additional subsidization opportunities. For example, the allocation of Principal Forgiveness to the communities most in need or most disadvantaged. The scaled scoring should also consider environmental justice and equity considerations in addition to mean household income (MHI) or income-only considerations. States like Iowa have a multi-parameter approach.

Are nitrate projects eligible for emerging contaminant funding from the Bipartisan Infrastructure Law?

It is our understanding that only projects to address contaminants that have not yet been regulated, are the ones that are eligible for emerging contaminant funding. However, projects to address PFAS are eligible.

My state’s IUP references “cross cutters,” what are those?

Cross-cutting federal authorities are the requirements of other federal laws and Executive Orders that apply in federal financial assistance programs. While a bit dated, the EPA still uses this handbook to understand how cross-cutting federal authorities affect SRF programs. You can also explore the Bipartisan Infrastructure Law Implementation Memo for further guidance on SRFs. 

Will the changes from the Bipartisan Infrastructure Law (BIL) to the Safe Drinking Water Act (SDWA) and the Clean Water Act (CWA) continue into the future?

Yes! The Bipartisan Infrastructure Law amended both SDWA and CWA, which includes new provisions applicable to the base SRF programs and, unless otherwise directed, are also applicable to projects funded in whole or in part with funds made available by BIL. Check out EPA’s FAQ document for additional information.

How can State Revolving Funds support projects related to nonpoint source pollution?

We recommend exploring the Confluence for Watershed Leaders. That group has done (among other things) some learning/sharing around CWSRF nonpoint source projects. Other resources include: Funding Agricultural Best Management Practices with the Clean Water State Revolving Fund (epa.gov); Grant Guidance CWA §319 Grant: Current Guidance | US EPA; OIG Report: Half the States Did Not Include Climate Adaptation or Related Resilience Efforts in Their Clean Water State Revolving Fund Intended Use Plans.

Are there any states that the Forum has prioritized in IUP engagement?

The Forum itself does not focus on specific states for advocacy, but members vae their own priorities. Check out our tracker to see what other advocates are up to!

Is it possible for a state to not have a public comment period?

That would be a violation and the USEPA would be obligated to deny IUPs without a public comment period. However, materials are often taken down after the required public comment window, adding to the difficulties of analyzing state practices across time. This report highlights similar challenges and provides recommendations for improving accessibility.

Is there a difference between what is listed in a Project Priority List (PPL) and what actually gets funded?

Yes, there can be depending on the state. For example, Illinois produces a PPL to indicate its priorities, but rely on a separate list called the Intended Funding List (IFL) to outline the subset of applicants that will have funding reserved for them. Moving from one list to another depends on various factors including available funding and readiness-to-proceed requirements. 

How is the money for state SRF programs determined?

Estimates of infrastructure need inform how much money EPA allocates to states. The Drinking Water Infrastructure Needs Survey and Assessment (DWINSA) is used to allocate DWSRF grants. The Clean Watershed Needs Survey (CWNS) is used to inform CWSRF grants, but allocations are ultimately governed by a set of allocation percentages contained in the Clean Water Act Section 205 (33 U.S.C. §1285(c)(3)). More can be done, recognizing that surveys largely rely on utility responses.

How do Utilities pay for their PFAS testing (with or without SRFs)?

The Bipartisan Infrastructure Law provides an unprecedented $9 billion to invest in drinking water systems impacted by PFAS and other emerging contaminants. Funds include $4 billion through the Drinking Water State Revolving Funds (SRF), including a requirement that states dedicate 25% of these resources to disadvantaged communities or public water systems serving fear than 25,000 people.

Outside of SRF programs, the law includes $5 billion to communities as grants through EPA’s new Emerging Contaminants in Small or Disadvantaged Communities (EC-SDC) Grant Program. In March 2024, Congress made a legislative change in the FY 2024 Consolidated Appropriations Act to include “owners of drinking water wells that are not public water systems or connected to a public water system” as eligible beneficiaries of FY24 funds.

Litigation could be a source of funding to support PFAS work. For example, states like California and Minnesota use proceeds from lawsuits, which rely on state regulations, to reduce the burden on rate payers. 

I want to connect with my utility and understand how they use state revolving funds. Do you have recommendations on how to approach them?

Connecting with your utility is a good step to advance SRF advocacy. Verde, a community-based organization, developed this template for outreach to utilities (and other community organizations) as part of PolicyLink and River Network’s Civic Engagement project. It contains sample language for email templates and key research questions to facilitate discussions. Please feel free to tailor it to your needs. Relationship building will take time; it’s helpful to engage community members in the service area of interest.