The purpose of the Clean Water and Drinking Water SRF programs is to eliminate existing water quality and public health problems. Projects to be funded by the SRF are selected using an objective point system that heavily favors projects with the greatest environmental benefits and that affect the greatest numbers of people. Application of these criteria has resulted in funding of projects that are concentrated in urban areas and that favor “fix it first” strategies of maintaining existing infrastructure over new development. Where projects that expand existing capacity do qualify under the selection criteria – as can be the case for example when widespread failing septic systems are replaced by sewers -- the program applies other restrictions that limit the potential for significant growth effects in greenfield areas. Building where the infrastructure (water, sewer, transportation) exists to support development, preserving sensitive ecosystems and open space, limiting growth to what the environment can support. The SRF supports planning ahead for water resources in two principal ways: 1. Applicants for significant SRF loans get priority points for having a comprehensive water resources plan, in which they address where growth will be located in their town and how water and wastewater services will be provided for that growth. Projects consistent with a management plan are more likely to be funded. 2. Enforcement actions against towns with wastewater capacity problems often require comprehensive planning, in which a town identifies areas for growth. SRF selection criteria emphasize work in already developed areas in three ways: 1. Wastewater project proponents are required to demonstrate that 75% of the flow within a new sewer system was in existence as of 7/1/95 (date of most recent Title 5 regulations). 2. Drinking water projects are prioritized based on size of population and existing public health problems, strongly favoring projects in more heavily developed areas. A proposal to develop a new system in an undeveloped area would almost certainly fail to be financed. 3. The SRF priority system similarly favors wastewater projects in areas of existing density and where there are public health impacts, leading to considerable funding of CSO and SSO projects, especially in urban areas. Additional incentives could be built into the SRF priority system to reward towns or regions with smart growth plans once the contents of the suitable plans are articulated. In addition, DEP could reduce the 25% existing flow threshold to reduce the amount of new flow capacity that could be included in a project receiving SRF financing. In those cases where new sewers are needed to remedy existing environmental or human health problems caused by widespread failing septic systems, stringent limits on new floe could be included, as was done on Plum Island and Provincetown.
BRP proposes to proceed with the solicitation for the Calendar Year 04 SRF priority list in May using exciting criteria. CLEAN WATER STATE REVOLVING FUND 2002-2003 Here is how the money has been spent in the clean water fund over the last two years. The first four categories, constituting 82% of the dollars loaned, are entirely infrastructure repair/replacement and land protection and water planning work, all of which support protection of green space and use of existing infrastructure. Only sewer projects (18% of the total) have the potential to support any significant growth. However, as is explained below, the growth that can occur through these projects is limited in amount and primarily focused on infill development not large Greenfield projects. Spreadsheets listing the funded projects for 2002 and 2003 are attached.
SRF Clean Water Projects ($$) 2002-2003
Combined sewer overflows Infiltration/inflow elimination Planning
Waste water treatment plants Land purchase Sewer
The first five categories of funded projects are entirely consistent with the idea of developing in areas of existing infrastructure, protecting existing greenspaces, and planning to locate development where the infrastructure exists Combined Sewer Overflow (CSO) occurs via cross contamination of sewer and stormwater drainage systems. These exist in older densely developed urban areas of the Commonwealth. Mitigation significantly reduces public health exposures in the community.
Wastewater Treatment Facilities across the state face massive burdens to update aging treatment systems while at the same time treating to increasingly more strict permit limitations. Infiltration & Inflow Elimination is normally accomplished by the repair and replacement of leaky pipes that siphon groundwater (infiltration) or by the elimination of connections from stormwater contribution to sewer system from illicit connections. Each of those sources contributes „clean stormwater to sewer, creating additional treatment costs and consuming WWTF capacity that could otherwise support development Land Acquisition/pollution prevention activities limit any future development and protect sensitive environmental resources, specifically the Assawompsett Pond complex water supply in southeastern Massachusetts. Water Resources Planning allows the community to evaluate the impacts of present and future development on water resources and to develop a strategy to provide for needs, protect resources and encourage thoughtful and appropriate use of technology. Stormwater Phase 2 planning by communities is a significant expense item within the planning category for these two years. The sewer projects (18%) do have some potential to support growth, but the potential impacts of these projects on sprawl is limited a number of ways. The principal constraint is the 1997 regulation that limits the amount of system expansion that may be funded. Under the rules, the proponent must demonstrate that 75% of the flow into the designed system emanates from properties that were developed before the July 1995 promulgation of Title 5 (septic) regulations. Therefore, only 25% new capacity is allowed for any sewer project. The program‟s experience is that any extra capacity is generally used for fill in development of lots in the service area that might have been vacant. The new capacity requested is often in response to MGL C83 s3, which provides that a property owner abutting a sewer line has the right to connect to the system. Treatment operators need the additional capacity to support new connections in already developed areas. Although these new additions are “growth,” they are generally in areas where infrastructure already exists, not in completely undeveloped areas. The Community Septic Management Program, administered within the SRF program provides homeowners with low interest loans to upgrade failed on-site septic systems. CSMP funds have also financed the cost of connections to sewer systems, for homeowners, provided that the home was serviced by a failed septic system. The Massachusetts investment in these activities has translated into the third largest volume of dollars in the nation spent on NPS projects and the largest residential on-site disposal repair system repair program in the nation. DEP also has, through its planning guidance, directed borrowers to evaluate the effect of the proposed projects on growth, in accord with E.O. 385, and to develop strategies to mitigate any potential negative growth effects.
SRF also mitigates its potential for encouraging sprawl by encouraging planning approaches that do not rely entirely upon centralized collection, but that employ a mix of centralized collection, small community systems and on-site individual systems. Finally, where new infrastructure is required to mitigate severe environmental or human health effects (e.g., in areas with failing septic systems that are contaminating drinking water or local surface water), DEP has worked with the communities to get special local legislation to strictly limit the potential for encouraging future development within the service area. Such special legislation is designed to supercede Ch 83, s3, and zoning code, in order to ensure that growth and expansion does not overwhelm the system or the service area. A good example of this approach is the Plum Island project. Plum Island has a demonstrated problem with septic contamination of both the drinking water and the environment, which after extensive study it was determined needed to be addressed by provision of treated drinking water and collection for treatment of wastewater. DEP worked with the towns to develop special zoning overlay districts so that only a very small number of additional infill units could be added to the system. DRINKING WATER STATE REVOLVING FUND 2002-2003 Here‟s how the money has been spent in the drinking water SRF over the last two years. Total Drinking Water SRF investments for 2002-2003 exceed $211 million. $172M of the $211M, or 82% of the program capacity, was used for projects that promote infrastructure rehabilitation. (See detailed project lists, attached)
SRF drinking water projects ($$) 2002 and 2003
Treat existing source Distribution system rehabilitation Enhanced treatment with expanded distribution
The first two categories of funded projects (82%) are entirely consistent with the idea of repairing existing infrastructure.
Water Treatment Facilities have secured a significant portion of the available SRF funding to finance upgraded treatment required to meet the Safe Drinking Water Act. Treatment projects help to eliminate existing public heath concerns within existing water systems. Distribution System rehabilitation ranks as the single biggest cost item confronting water suppliers across the state. Tuberculation (constriction of the interior diameter of the pipe due to oxidization), breaks, vinyl lining, and asbestos cement piping in existing distribution all contribute to health risk. Distribution system rehabilitation projects significantly reduce or eliminate those threats. The DW SRF program also finances projects to optimize and in some instances construct new treatment and distribution systems. In 2002-2003, the cost of those projects was about 18% of the total. Typically, these consist of increases in the size of water mains to address pressure problems. Another use of DW SRF has been to consolidate an existing, under-performing PWS into a larger and appropriately managed system. SRF has also financed the reclamation of contaminated sources, which have become supplemental sources and/or emergency sources for PWS. DWSRF does not finance planning in the same manner as the CWSRF. Safeguards afforded by the water Management Act, the Interbasin Transfer Act, New Source Approval Process and MA Environmental Policy Act, including conservation measures, leak detection & elimination and demand management, were determined by the program to provide an adequate level of control, so additional planning requirements were not added to the DW SRF process, to avoid additional expenses to the Public Water Suppliers.
SRF FUTURE SOLICITATIONS Under the present criteria, the SRF primarily funds projects that are entirely consistent with a “Fix It First” strategy, as is evidenced by the enormous investment in CSO mitigation, water treatment facilities, wastewater treatment facilities and rehabilitation of water distribution and wastewater collection systems. The SRF Needs Surveys show that billions of dollars in existing infrastructure improvements are needed in Massachusetts. Given that the weighting system DEP uses to select projects heavily favors projects in areas of existing development, the huge emphasis in funded projects on infrastructure rehabilitation is likely to continue into the indefinite future. SRF projects are driven by the selection criteria, which are derived from the planning goals developed by the Department. The same regulatory framework that provides flexibility in amending selection criteria provides the Department with the ability to focus or refocus its planning goals. As the specific goals and methodologies for Smart Growth planning and implementation are developed and institutionalized, the SRF programs can and will incorporate those into its planning guidance.
DEP notes that the SRF is not the only source of financing for drinking water and wastewater construction projects. Communities use their own financing as well as economic development funds from state and local sources to construct water infrastructure. Anecdotal evidence suggests that a number of projects financed from nonSRF sources are incorrectly thought by opponents to be SRF projects, with the SRF program erroneously identified as the culprit in supporting sprawl. The (mis) impression that the SRF program is a major component in sprawl in Massachusetts, clearly refuted by the data, may in part result from the assumption that all water infrastructure development is supported by SRF dollars.