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CIFA launched More Protection, Less Process, to advocate for relief from duplicative paperwork and processes that deter communities from utilizing SRF loans to undertake much needed water infrastructure.



Improving compliance procedures for federal requirements will reduce costly administrative barriers to greater investment in water infrastructure which will ultimately increase protection for public health and the environment.

Download the Policy Position: More Protection, Less Process for the Clean Water State Revolving Fund

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Federal requirements on SRF loans have increased significantly during the last decade. See the growth in federal requirements since 2009. While well intentioned, many of the federal loan requirements are duplicative of state law and add to the administrative cost of water infrastructure projects, making SRF loans less attractive to potential borrowers.

According to a 2018 survey of CIFA members, the cumulative impact of compliance with federal requirements was cited as the number one issue for communities considering an SRF loan. As a result, many communities are delaying or simply not pursuing much needed water infrastructure projects.

Policy Recommendations

To support greater investment in water infrastructure, CIFA developed policy recommendations to reduce duplicative paperwork and processes related to federal requirements. The policy position:

  • Maintains requirements for applicants to ensure mechanics and laborers are paid prevailing wages (Davis Bacon) but offers alternatives for demonstrating compliance with the federal requirement. 

  • Maintains requirements to buy products made with American iron and steel but recommends development of an inventory to facilitate procurement of verified products.

  • Recommends flexibility and funding to support best management practices.

  • Maintains reporting of the capitalization grant into the national database required by the 2010 Federal Funding and Accountability Transparency Act (FFATA), but eliminates the requirement to enter loan recipients into the system. 

  • Eliminates the requirement to use the federal procurement process for architectural and engineering services.

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