NACWA Comments on EPA’s New Allocation Formula for Sewer Overflow, Stormwater & Reuse Grants

(September 10, 2020) – NACWA submitted comments September 3 to EPA on the Agency’s new proposed allocation formula for the Sewer Overflow and Stormwater Reuse Municipal Grants Program.  These comments come after EPA issued a notice in early August seeking public feedback on a proposed allocation formula for distributing grant money to states through this program, which has recently been funded for the first time.   

NACWA’s comments note that the proposed allotment formula employs  a series of factors that  to determine the distribution of the grant funds in a manner that best reflects the need for wastewater, stormwater and water reuse investment. The proposed allocation formula will distribute funds to states based on a weighted scale that considers the most recent Clean Watersheds Needs Survey (CWNS)(50%), total population (16.67%), urban population (16.67%), and annual average precipitation (16.67%).

While NACWA understands that some parts of the country may have varying opinions on the various components of the formula, the Association believes that the proposal overall will—when combined with existing funding programs like the Clean Water State Revolving Fund and the Water Infrastructure Finance and Innovation Act (WIFIA) program—help direct federal funds towards investment projects most in need of federal assistance.

However, because the bulk of the allocation formula relies on the CWNS, there is significant concern with the outdated data in the most current 2012 CWNS Report. The CWNS to date has served as an informational tool for members of Congress and the public on clean water needs, but it has never been used for specific funding allocations.

The data collected by the CWNS historically has varied in consistency, in large part because there is no funding set aside for states and EPA to collect the data, and because there is little incentive for complete and accurate reporting of the needs, resulting in significant gaps in the data. The lack of dedicated funding has also led to major delays in the traditional four-year reporting timeframe. NACWA’s comments emphasize the importance of improving data collection and timeliness for the CWNS to ensure it is as accurate as possible, especially given its new role in helping allocate funding

EPA’s Sewer Overflow and Stormwater Municipal Grants Program was originally authorized over 20 years ago but funding was never appropriated. NACWA has worked diligently with Congress to get the program reauthorized and updated through the 2018 America’s Water Infrastructure Act (AWIA) process and helped secure $28 Million in appropriations for the first round of funding EPA will distribute to states.

If members have questions, please contact Emily Remmel, NACWA’s Director of Regulatory Affairs.