Environmental Loans January 2025 Newsletter
The Wisconsin Department of Natural Resources (DNR)’s 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.
Rescission Of Bipartisan Infrastructure Law Signage Requirement
On Dec. 5, 2024, the Environmental Protection Agency’s Office of Grants and Debarment rescinded the Bipartisan Infrastructure Law (BIL) Signage Requirement that applied to construction projects funded in whole or in part by the BIL. Therefore, the BIL Signage Requirement is no longer in effect. Note: Projects designated as federal equivalency by the DNR still have a signage/public awareness requirement. Non-federal equivalency projects do not have a signage requirement.
Consequently, the Clean Water Fund Program and Safe Drinking Water Loan Program will no longer enforce the BIL Signage Requirement.
The BIL sign and related expenses are still eligible costs for financial assistance recipients who are in the midst of the process or have already procured, built and/or installed the sign prior to Dec. 5, 2024. If existing BIL signs are damaged, they do not need to be replaced. Existing BIL signs can be removed or remain installed.
Federal Equivalency Requirements
For DNR-designated federal equivalency projects with loans executed on or after Dec. 5, 2024, those projects must instead meet the signage/public awareness requirements in the June 2015 Guidelines for Enhancing Public Awareness of State Revolving Fund Assistance Agreements. The BIL signage will still satisfy the signage/public awareness requirement, or the recipient can choose a different option from the guidelines.
Direct questions related to the rescission of the BIL Signage Requirement to Casey Sweeney, DNR Environmental Loans Section program and policy analyst, at Casey.Sweeney@wisconsin.gov or 608-852-1576.
Important Update: Increased Single Audit Threshold
The Office of Management and Budget (OMB) has revised the Uniform Guidance and released the final updated version in April 2024. As part of these updates, the Single Audit threshold has increased from $750,000 to $1,000,000.
This change will take effect for fiscal periods beginning on or after Oct. 1, 2024. Entities that annually expend less than $1 million in federal funds during their fiscal year will no longer be subject to a Single Audit under the new threshold.
The Wisconsin Department of Administration (DOA) sent notification to all municipalities that may need a Single Audit for funds received between Jan. 1, 2024, and Dec. 31, 2024. The $750,000 threshold applies to the calendar year 2024 receipts.
If you have any questions or need assistance understanding how this change impacts your organization, please don't hesitate to contact us at DOAEIF@wisconsin.gov.
Context
Section Adm 35.07(3), Wis. Adm. Code, requires a recipient of Clean Water Fund Program and/or Safe Drinking Water Loan Program financial assistance with a project(s) designated as federal equivalency by the DNR to comply with the Single Audit Act (31 USC 7501 to 7506) and the OMB’s Uniform Guidance (2 CFR Part 200). Read the Federal Single Audit Act Requirements for Federal Equivalency Projects article on page 2 of the Environmental Loans Newsletter published on Dec. 21, 2023.
Submit Facilities Plan By End Of March 2025 For State Fiscal Year 2026 Clean Water Funding
An approved facilities plan is required for all Clean Water Fund Program projects, regardless of project classification. A facilities plan covers federal requirements such as the cost-effectiveness analysis and the environmental analysis. Even projects that do not fit under the definition of a “reviewable project” under chapter NR 110, Wis. Adm. Code, must complete a facilities plan to be eligible for Clean Water Fund Program funding. For requirements, see the Municipal Wastewater Facility Planning webpage.
For sanitary sewer replacement or rehabilitation projects, an abbreviated facilities plan or engineering report can often fill the requirement of a facilities plan. View the “Collection System Projects” section of the Municipal Wastewater Facility Planning webpage for a list of what elements should be included in an engineering report.
It is strongly recommended that the facilities plan is submitted to the DNR Bureau of Water Quality at least six months prior to the Clean Water Fund Program application deadline, to allow sufficient time for review and approval. Since the state fiscal year 2026 Clean Water Fund Program application deadline is Sept. 30, 2025, facilities plans should be submitted to the DNR by the end of March 2025.
Applicants must upload a facility plan approval letter with their application for the application to be considered complete.
In addition, facilities plans can only be approved if construction has not yet commenced. If there is any chance a project will seek Clean Water Fund Program funding, then it is encouraged that a facility plan is submitted and approved prior to construction commencing. If the facility plan cannot be approved, then the Clean Water Fund Program cannot fund the project.
New Population Projections Published By DOA
The Department of Administration’s (DOA) Demographic Services Center has recently published updated population projections based on the 2020 Census. Going forward, proposed facilities plans must be in conformance with these updated population projections, pursuant to s. NR 110.09(2)(j)1., Wis. Adm. Code.
For questions on the facilities plan requirement, please contact DNR wastewater systems plan review staff.
Plan Reviews For State Fiscal Year 2026 Safe Drinking Water Funding
A review of project plans and specifications by the DNR Bureau of Drinking Water and Groundwater is a mandatory step in the process of applying for and receiving Safe Drinking Water Loan Program funding. If your municipality is seeking to submit a financial assistance application for the state fiscal year 2026 Safe Drinking Water Loan Program by the principal forgiveness application deadline of June 30, 2025, then you must also submit the project to the DNR Bureau of Drinking Water and Groundwater for plan review by no later than the June 30 application deadline. This submittal requirement is in addition to the requirement to upload plans and specifications to the online application. We recommend that you submit the project for plan review well before the application deadline, when possible, to ensure adequate time for review.
Determine and follow the plans and specifications and engineering report submittal requirements from the DNR Drinking Water and Groundwater Bureau:
The DNR routinely updates forms, so check the website regularly for the most up-to-date information.
We encourage you to reach out to the DNR public water plan reviewers early on with questions and concerns. Staff can offer technical comments that might expedite approval and help you determine an appropriate submittal timeline. To contact plan reviewers, email DNRPublicWaterPlanReview@wisconsin.gov.
Engineering Reports
Certain project categories require an engineering report to be submitted as part of the plan review process. If an engineering report is required for your state fiscal year 2026 project, it can be submitted before or along with the plans and specifications to the DNR Drinking Water and Groundwater Bureau for review by the June 30, 2025 application deadline. The engineering report should comply with the applicable engineering report requirements contained in chapters NR 108 and NR 811, Wis. Adm. Code, for the type of project being constructed.
Plans And Specifications
Submit the required copies of the final plans and specifications for the project to the DNR Drinking Water and Groundwater Bureau for review and approval as required under ch. NR 108 or NR 811, or both, through the Public Water System Plan Review process by the Safe Drinking Water Loan Program application deadline. In addition, submit a copy of the final plans and specifications with the Safe Drinking Water Loan Program application for the project to the DNR Environmental Loans Section via the Online Application System by the Safe Drinking Water Loan Program application deadline. A municipality may submit the final plans and specifications for review prior to or at the time of application.
Final plans and specifications indicate the documents are complete, biddable and approvable, for all parts of the project being financed through the Safe Drinking Water Loan Program. They must also include a seal or signature indicating that they were prepared under the supervision of a professional engineer licensed in Wisconsin. Note: For new well projects, the plans and specifications for the drilling of a permanent well must be submitted by the Safe Drinking Water Loan Program application deadline. The wellhouse, treatment or other site-specific, well-related plans may be submitted following final well construction. Plans and specifications would need to be approved by the DNR in time to meet the loan closing deadline.
DNR Approval
The DNR approval letters for the engineering report and the plans and specifications are not required at the time of application. However, upload the approval letters to the online application if they are available at the time that you submit the application. Plans and specifications approval by the DNR is required prior to preparation of the Safe Drinking Water Loan Program financial assistance agreement (loan).
Obtain Plan Review Approvals Prior To Starting Construction
Commencing construction of any reviewable project without first obtaining the DNR’s written approval of the final plans and specifications for the project is a violation of s. NR 108.03(1). Additionally, the DNR is prohibited from approving plans and specifications for any project for which construction has commenced, per s. NR 108.04(5). Any entities that commence construction without DNR plan approval are ineligible for the Safe Drinking Water Loan Program funds.
Available Lead Service Line Replacement Outreach Funding
Reduce the struggles of starting and completing lead service line replacement projects via effective community outreach and public education. These efforts can help residents, property owners, consumers and community leaders understand the importance and process of lead service line replacements.
If community members know what to expect, it will likely reduce their concerns, increase their cooperation, and make for successful lead service line replacements. The Wisconsin Department of Natural Resources (DNR)’s Lead Service Line Replacement Community Outreach Grant Program, funded through the Bipartisan Infrastructure Law, provides communities with the funding needed to coordinate this crucial outreach.
The purpose of this program is to provide eligible municipal community public water systems with the funds to carry out on the ground community outreach to residents served by the system in support of an ongoing or upcoming lead service line replacement project. This funding does not cover construction costs, including any construction associated with lead service line replacement.
“We are pleased to offer this grant funding to help community public water systems obtain outreach assistance for lead service line replacement,” said Steve Elmore, DNR Drinking Water and Groundwater Bureau director. “One thing we have learned is that community outreach is key in successful lead service line replacement. This grant is helping move this initiative forward in Wisconsin.”
The DNR encourages interested applicants to review the Lead Service Line Replacement Community-Outreach Grant Announcement for detailed eligibility information and instructions on preparing an application.
- Applications will be accepted continually until April 30, 2025, or until funds are exhausted, whichever comes first.
Learn more about the Lead Service Line Replacement Community Outreach Grant Program on the Lead Service Line Replacement Outreach Funding webpage.
Direct questions about this grant and program to DNRLSLROutreachGrants@wisconsin.gov.
Context
Lead can enter drinking water through the corrosion of the property’s plumbing materials and the water service line(s) connecting the property to the water main(s). Lead is known to be harmful to human health if ingested. It is critical for municipalities to replace both publicly and privately owned portions of a lead service line because partially replacing it can increase lead levels in the home’s drinking water. The DNR Drinking Water and Groundwater Bureau provides information and resources regarding the concerns of lead in drinking water.
Suzy Hasheider Is New Policy Analyst For Safe Drinking Water Loan Program
The Environmental Loans Section is pleased to announce that Suzy Hasheider is our new federal and state policy analyst for the Safe Drinking Water Loan Program.
Please join us in congratulating Suzy on her new position! She started as our policy analyst on Jan. 13, 2025. Suzy can be contacted at Suzan.Hasheider@wisconsin.gov or 608-438-3055.
In her new role, Suzy is responsible for tracking state and federal rules and regulations that apply to the Safe Drinking Water Loan Program, coordinating with the U.S. Environmental Protection Agency and DNR programs on policy and budget initiatives and serving as a loan project manager. Casey Sweeney, the current federal liaison, is shifting his Safe Drinking Water Loan Program duties to Suzy but will continue to manage federal policy for the Clean Water Fund Program while adding state-level Clean Water Fund Program responsibilities.
Suzy has a B.S. in Environmental Science from the University of Michigan-Flint and a M.S. in Water Resources Management from the University of Wisconsin-Madison. In 2014, Suzy began her career with the Wisconsin DNR. Suzy brings policy experience such as writing permits, guidance, rule language and permittee outreach to her new position from her seven years with the DNR’s Storm Water program. Since November 2021, Suzy has served as the database manager for the Environmental Loans’ systems. Suzy will do what she can to keep the online system improvements moving forward until her previous position is filled.
Upcoming Deadlines And Events
The deadlines for the notice of intent to apply, application and loan closing are set in the corresponding program's annual intended use plan, see the Project Lists and Intended Use Plans webpage.
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Winter 2024-25: The DNR intends to publish the state fiscal year 2025 Lead Service Line Replacement Program final funding list.
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March 31: The last recommended date for submitting facilities plans to the DNR Bureau of Water Quality for the state fiscal year 2026 Clean Water Fund Program funding cycle.
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Late winter/spring 2025: The DNR intends to publish the state fiscal year 2026 Clean Water Fund Program and Safe Drinking Water Loan Program project priority lists.
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April 30: The last recommended date for opening bids for the state fiscal year 2025 Clean Water Fund Program and Safe Drinking Water Loan Program projects.
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May 31: Executed construction contracts due to the DNR loan project manager for the state fiscal year 2025 Safe Drinking Water Loan Program projects (earlier submittal is encouraged).
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Late spring 2025: The DNR intends to publish the state fiscal year 2026 Clean Water Fund Program and Safe Drinking Water Loan Program draft intended use plans for respective public comment periods.
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June 15: Public Service Commission-approved rate orders due to the DNR loan project manager for the state fiscal year 2025 Safe Drinking Water Loan Program projects.
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June 30: Application deadline if competing for principal forgiveness for the state fiscal year 2026 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 June 30 deadline due to potential limitations on loan capacity. See the Loan Capacity webpage for more information. Note the following reminders:
- Plans and specifications must be uploaded to the online application AND submitted to the DNR Bureau of Drinking Water and Groundwater through the public water system plan review process by the application deadline.
- The period to submit both an appeal to an eligibility determination and a priority score reevaluation request opens the day after the application deadline and runs for a period of 30 days.
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June 30: Readiness-to-proceed deadline for the state fiscal year 2025 Clean Water Fund Program principal forgiveness projects. All required bid documentation, including executed construction contracts, are due. Failure to meet this deadline will result in principal forgiveness funds being forfeited.
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Sept. 30: Application deadline if competing for principal forgiveness for the state fiscal year 2026 Clean Water Fund Program funding cycle. The DNR recommends that all applicants (even those not competing for principal forgiveness) submit an application by the Sept. 30 deadline due to potential limitations on loan capacity. See the Loan Capacity webpage for more information. Note the following reminders:
- A facility plan approval letter must be uploaded to the online application for all projects.
- Plans and specifications must be uploaded to the online application AND submitted to the DNR Bureau of Water Quality through the wastewater plan review process by the application deadline.
- The period to submit a priority score reevaluation request opens the day after the application deadline and runs for a period of 30 days.
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