  |
|
|
Email comments on this rule | Send comments by mail | Return to Main Page
|
|
||
| Present Provision: | Challenges: | Questions or Comments: |
| The federal Clean Water Act requires the SRF program to be self-sustaining | A recent study on the sustainability of the SRF program determined that the current interest rates are too low to ensure Fund perpetuity | State Revolving Fund Perpetuity and Interest rates |
|
|
||
| Present Provision: | Challenges: | Questions or Comments: |
| The current
hardship threshold is a sewer rate of 1.5% of median
household income. Rates higher than 1.5 indicate
hardship. Hardship funding usually consist of longer loan terms, lower interest rtes, companion grants, and occasionally an unemployment differential. |
Declining revenue About 20% of SRF portfolio is at zero (0%) interest Maintaining perpetuity Can some communities afford some level of interest on loans? Making loans affordable for communities that demonstrate hardship |
Hardship Provisions |
|
|
||
| Present Provision: | Challenges: | Questions or Comments: |
| Two-thirds (2/3) of competitive funding is set aside for facilities hardship grants, and one-third (1/3) is set aside for nonpoint activities grants such as TMDL implementation. | What is an appropriate
allocation? Does the current allocation still work? |
Allocation for Centennial Grants for Facilities and Activities |
|
|
||
| Present Provision: | Challenges: | Questions or Comments: |
| Activities--$250,000 grant
with a 25% cash, in-kind, or interlocal match, or $500,000 grant with a 25% cash only match. Activities--loan ceiling of $500,000 with no matching requirement |
Are ceiling amounts
appropriate? Do they suit current and emerging needs? |
Maximum Financial Assistance Provisions--Centennial |
|
|
||
| Present Provision: | Challenges: | Questions or Comments: |
| Present rule criteria are:
1. Public health & water quality impairments--34% 4. State of Washington or federal mandates project addresses-10% 5. Local Priority setting-10% |
What is an appropriate benchmark to set baseline priorities? | Evaluation Criteria |
|
|
||
| Present Provision: | Challenges: | Questions or Comments: |
| No provisions in rule for a cutoff level in which projects that fall below that level would not be funded. However the Joint Legislative Audit and Review Committee (JLARC) recommended consideration | What is the appropriate benchmark or cutoff level in which to consider projects for funding? | Funding Threshold |
|
|
||
| Present Provision: | Challenges: | Questions or Comments: |
| Grant eligible BMPs are currently limited to the riparian (streamside) corridors, for activities such as fencing and revegetation | Limited grant dollars Appropriate use of public funds on private property |
Grant Eligibility --Best Management Practices (BMPs) on Private Property |
|
|
||
| Present Provision: | Challenges: | Questions or Comments: |
| The existing rule provisions permit Ecology to enter into "Step 4" Design-Construct agreement for relatively small projects that do not exceed $1 million of the total eligible project costs funded through Ecology | Ecology has been asked to
raise the ceiling amount for "Step 4" to reflect higher construction
costs. Projects that have completed facilities planning (only) often face unknown issues that can prevent the progression through the design and into construction in a timely way |
"Step-4"Design-Construct |
|
|
||
| Present Provision: | Challenges: | Questions or Comments: |
| No formal rule, but there is an SRF pilot rule in place that provides for large- scale, long-term loans under this provision. AC/SA projects can proceed without first completing the "STEP" process (plan, design, build) in which one step must be completed before the next step is started. | Obligating the entire project
costs from the SRF may result in financially distressed communities
receiving hardship loans. Large-scale, long-term, and low-interest loans threaten the perpetuity of the SRF At what point should an entity apply for funding (after they've secured the design team . .?) |
Alternative Contracting/Service Agreements (AC/SA--Design/Build) |
|
|
||
| Present Provision: | Challenges: | Questions or Comments: |
| Existing rules contain
"measures of success" as an evaluation criterion The Joint Legislative Audit and Review Committee (JLARC) recommended, and the Legislature mandated (in 2002) that Ecology implement a more formal outcome-based strategy |
Outcomes take time to document Resources to document the measures are limited Requirements may need more regulatory direction to address the statute |
Outcome Funding |
|
|
||
| Present Options: | Challenges: | Questions or Comments: |
| Shorter timeframe--complete
process for all issues and implement rule amendments for the Fiscal Year
(FY) 2007 funding Cycle Shorter timeframe--narrower scope of work--only amend "financial aspects" of the rule and amend the "technical" aspects later. Longer timeline--complete process for all issues and implement for FY2009 funding cycle |
May need more time for
adequate/thoughtful input
Can the financial and technical issues be effectively separated or is it detrimental to try and separate them? Longer timeline may jeopardize perpetuity of the SRF Fund |
Timeline for The Rule Amendment Process |
|
|
||
| Present Options: | Challenges: | Questions or Comments: |
| Miscellaneous comments not found under topics above | ||
Copyright © Washington State Department of Ecology. See http://www.ecy.wa.gov/copyright.html.
