Environmental Loans May Newsletter
The Environmental Loans programs provide affordable financial assistance to Wisconsin communities for water infrastructure projects that protect and improve public health and water quality for current and future generations.
Safe Drinking Water Loan Program Project Priority List Published
The Wisconsin Department of Natural Resources (DNR)'s Environmental Loans Section published the state fiscal year 2025 Safe Drinking Water Loan Program project priority list on the Project Lists and Intended Use Plans webpage on May 6, 2024. This project priority list identifies all projects with a valid notice of intent to apply, in priority score order, that are eligible to submit a Safe Drinking Water Loan Program financial assistance application for the state fiscal year 2025 funding cycle.
Please direct questions to Noah Balgooyen, DNR Safe Drinking Water Loan Program coordinator, at 608-720-0802 or Noah.Balgooyen@wisconsin.gov.
Note that the state fiscal year 2025 Clean Water Fund Program project priority list was published on April 18, 2024.
Upcoming Deadlines And Events
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May 31: Executed construction contracts due for the state fiscal year 2024 Safe Drinking Water Loan Program projects.
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June 15: Public Service Commission-approved rate orders due for the state fiscal year 2024 Safe Drinking Water Loan Program projects.
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July 1*: Application deadline if competing for principal forgiveness for the state fiscal year 2025 Safe Drinking Water Loan Program funding cycle. The DNR recommends that all applicants (even those not competing for principal forgiveness) submit an application by the July 1 deadline due to potential limitations on loan capacity. See the Loan Capacity webpage for more information. Note the following reminders:
- Submit the plans and specifications to the DNR Bureau of Drinking Water and Groundwater and with the Safe Drinking Water Loan Program application.
- Priority score reevaluation requests are due within 30 days of the Safe Drinking Water Loan Program application deadline date.
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July 1*: Readiness-to-proceed deadline for the state fiscal year 2024 Clean Water Fund Program principal forgiveness projects. All required bid documentation, including executed construction contracts, are due.
*If a deadline falls on a weekend or legal holiday, that deadline is extended to the next business day, per s. 990.001(4), Wis. Stats.
State Fiscal Year 2025 Applications Must Follow New Codes
The current versions of chs. NR 162 and NR 166, Wis. Adm. Code, became effective on Nov. 1, 2023. All state fiscal year 2025 Clean Water Fund Program and Safe Drinking Water Loan Program projects must follow the current rules. It does not matter that the notice of intent to apply was submitted before the effective date because the financial assistance applications will be submitted after it.
Links to both the current and former versions of the rules are available on the Statutes and Administrative Codes webpage. The DNR strongly recommends that you review the appropriate version of the code when looking at requirement and eligibility questions because we are in the process of publishing updated webpages and publications. More details about the rule revisions will be forthcoming in future newsletters, updates and a summary of rule revisions.
Design Life Calculation Worksheet Is Required For All Projects
Beginning with state fiscal year 2025 projects, the Design Life Calculation Worksheet is now required for all projects (even 20-year loan terms) unless the project consists solely of installation or replacement of pipeline and associated appurtenances. The Clean Water Fund Program and Safe Drinking Water Loan Program Design Life Calculation Worksheets are available on the Loan Terms webpage. Both Excel and PDF versions of the completed Design Life Calculation Worksheet must be uploaded with the financial assistance application. For more information, see the corresponding program’s intended use plan.
Unique Entity ID Update
The Unique Entity Identifier (generated by SAM.gov) is now only required for federal equivalency projects. The DNR will indicate on the corresponding project priority list which projects meet the criteria to be designated as federal equivalency. Municipalities with federal equivalency projects must have an active Unique Entity ID.
- Use the Entity Status Tracker tool to determine whether your entity’s ID is in “Active” status.
- New entities can get their ID on the registration webpage and, if required, complete an entity registration. Registration times vary and can take up to 10 business days to become active.
- Existing registered entities can find their ID by following the steps on this webpage. You must renew your entity’s registration every 365 days to keep it active.
New Environmental Review Requirement
Information for Planning and Consultation (IPaC) review documentation must now be uploaded in the environmental review module of the Safe Drinking Water Loan Program online application system. The Environmental Review Guide (PUB-CF-060) has been updated with instructions for using the U.S. Fish and Wildlife Service’s IPaC system to generate this documentation. Direct Safe Drinking Water Loan Program environmental review questions to DNRCFELEnvironmentalReview@wisconsin.gov.
BABA Applicability In The Lead Service Line Replacement Program
The DNR has received updated guidance from the U.S. Environmental Protection Agency (EPA) regarding Build America, Buy America (BABA) applicability in the Bipartisan Infrastructure Law-funded Lead Service Line Replacement Program. This includes a reversal of previous guidance the DNR provided, which stated that private side replacements done utilizing a prequalified list of plumbers/contractors were exempt from BABA under the small projects waiver; that is no longer true. Here is a quick rundown of how BABA applies to lead service line replacement projects.
When BABA Applies
- BABA applies to public side replacements when the total of the financial assistance agreement (loan) is $250,000 or greater.
- BABA applies to private side replacements when the loan is secured by a water revenue pledge and the total of the financial assistance agreement is $250,000 or greater. (Public Service Commission approval is required for private side replacements utilizing a water revenue pledge.)
When BABA Does Not Apply
- BABA does not apply to public or private side replacements when the total of the financial assistance agreement is less than $250,000 (exempt under the small projects waiver).
- BABA does not apply to private side replacements when the loan is secured by a general obligation note pledge or the new option of an alternative revenue pledge. This interpretation is based on the answer to question 8.3 in the EPA’s May 2023 memorandum. The EPA further clarified that utilizing a water revenue pledge constitutes “financial assistance from the water system.” They also clarified that the answer to question 8.3 does not just apply to single family homes as used in the example.
- BABA does not apply to private side replacements that receive a 100% principal forgiveness award.
If you have any BABA applicability questions, or other Lead Service Line Replacement Program questions, please contact Kate Leja-Brennan, lead service line specialist, at Kathryn.Leja@wisconsin.gov or Becky Scott, Environmental Loans section manager, at Rebecca.Scott@wisconsin.gov.
Current Discount Rate For Cost-Effective Analysis
All wastewater facility plans require a cost-effectiveness analysis to ensure that only the minimum required resources (monetary, environmental and social) are expended over the 20-year planning period. Present worth factors must be based on the current discount rate provided by the DNR in accordance with s. NR 110.09(1)(a), Wis. Adm. Code. The DNR will be using the 20-year real discount rate provided annually by the Office of Management and Budget in OMB Circular No. A-94 Appendix C.
- The 20-year real discount rate for the 2024 calendar year is 2.5%.
Read about the cost-effectiveness analysis on the Municipal Wastewater Facility Planning webpage. If you have any questions about a facility plan cost-effectiveness analysis, contact DNR municipal wastewater plan review staff.
Asset Management Training For Wastewater Systems
The Environmental Finance Center Network is offering free workshops on Asset Management for Wisconsin Wastewater Systems. These identical trainings will explore the core components of asset management and its practical application, using real-world examples to illustrate data-informed decision-making. This training is approved for 5.5 hours of continuing education credits for Municipal Waterworks and Wastewater by the Wisconsin DNR.
For more information and to register, visit the Environmental Finance Center Network’s training and events webpage.
Workshop #1: Danbury, Wisconsin
Date: Tuesday, May 14, 2024
Time: 9 a.m. – 4 p.m. CDT
Location: St. Croix Casino Danbury, 30222 State Road 35 #77, Danbury, WI 54830
Workshop #2: Keshena, Wisconsin
Date: Wednesday, May 15, 2024
Time: 9 a.m. – 4 p.m. CDT
Location: Menominee Nation College Culture Learning Center, N172 WI-47 #55, Keshena, WI 54135
Contact Information
Program-related questions can be sent to the appropriate coordinator:
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