On June 16, 2016, the California Water Association (CWA) submitted two comment letters on Intended Use Plans (IUPs) to the State Water Resources Control Board (SWRCB). The IUPs deal with the Drinking Water and Clean Water state revolving funds for fiscal year 2016-17 and outline the SWRCB’s business plans for the two funds, including revised Water Quality, Supply and Infrastructure Improvement Act of 2014 (Proposition 1) guidelines. According to the SWRCB, these two funds are critical in providing financing for projects that supply clean and safe drinking water as well as creating better water quality and sustainable and reusable water resources.

The Drinking Water fund, established in 1996 as part of the Safe Drinking Water Act, offers financial assistance to public water systems for drinking water infrastructure improvements. The Clean Water Fund, established in 1989 under the Clean Water Act, funds projects such as wastewater treatment and water recycling facilities; wastewater collection systems; and non-point source or estuary projects. The IUPs explain the types of projects the State Water Board anticipates funding this year and identifies the appropriate financing terms. These use plans are required under federal regulations and are submitted to the U.S. Environmental Protection Agency to receive grant funding.

CWA’s first letter addressed the draft 2016 Drinking Water State Revolving Fund (DWSRF) IUP for 2016-17 and the revised guidelines for implementing the Proposition 1 Drinking Water Program (Prop 1 Program). Acknowledging the water utilities regulated by the California Public Utilities Commission (CPUC) are generally eligible for grants and loans under the DWSRF-Prop 1 Program, CWA noted the utilities remain ineligible for the principal forgiveness component of capitalization grants and financial assistance in disadvantaged or severely disadvantaged communities (DACs and SDACs). To remedy the inequities, CWA is sponsoring Senate Bill 1456 to expand eligibility to all community water systems with fewer than 3,300 service connections serving DACs and SDACs.

PUCCWA’s second letter focused on the draft 2016 Clean Water State Revolving Fund (CWSRF) IUP for 2016-17 in conjunction with the Prop 1 Program. CWA’s letter asked the SWRCB to clarify in its updated IUP that CPUC-regulated water utilities are eligible for identified projects under the CWSRF Program. CWA’s letter also asked that Section D be added to the IUP introduction spelling out the eligibility for regulated water and wastewater utilities.

The SWRCB considered CWA’s comments in both IUPs, and CWA was satisfied with the final plans, which were approved by the SWRCB on June 21.

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