The U.S. Department of the Treasury recently released updated guidance on how communities can use their American Rescue Plan Act Local Fiscal Recovery (LFR) Funds. The Interim Final Rule offers an expanded interpretation regarding the types of sewer, water, and broadband infrastructure projects that qualify for funding, “allowing for a broad range of necessary investments in projects that improve access to clean drinking water, improve wastewater and storm water infrastructure systems, and provide access to high-quality broadband service” (Treasury.gov).
ARPA INTERIM FINAL RULE
HIGHLIGHTS ON USE OF FUNDS FOR SEWER & WATER INFRASTRUCTURE PROJECTS
Because municipalities have a broad range of water and sewer infrastructure needs, the Interim Final Rule provides wide latitude to identify investments in water and sewer infrastructure that are of the highest priority for your community, which may include privately-owned infrastructure projects.
Funds must be obligated by December 31, 2024, but recipients have until December 31, 2026 to complete projects using LFR funds.
Counties and metropolitan cities must request LFR funds through the Treasury Submission Portal. Non-entitlement communities will receive funds directly from the State.
ELIGIBLE PROJECTS
The Interim Final Rule aligns eligible uses of the LFR funds with the types of projects that are eligible to receive financial assistance through the EPA’s Clean Water State Revolving Fund (CWSRF) and/or Drinking Water State Revolving Fund (DWSRF). However, use of LFR funds is not limited to such projects. The Treasury specifies, “The Interim Final Rule is intended to preserve flexibility for award recipients to direct funding to their own particular needs and priorities and would not preclude recipients from applying their own additional project eligibility criteria.”
Projects may include, but are not limited to:
Water treatment, transmission, and distribution (including lead service line replacement)
Source rehabilitation and decontamination
Water storage
Water system consolidation
New systems development
Construction of publicly owned treatment works
Nonpoint source pollution management
National estuary program projects
Decentralized wastewater treatment systems
Storm water systems
Water conservation, efficiency, and reuse measures
Watershed pilot projects
Energy efficiency measures for publicly-owned treatment works
Water reuse projects
Security measures at publicly-owned treatment works
25 WATER AND SEWER RELATED INFRASTRUCTURE IMPROVEMENT PROJECTS
It’s unsurprising that many Wisconsin municipalities have expressed an interest in using LFR Funds for water and sewer related projects, as such infrastructure investments can improve a community’s overall quality of life for decades to come.
To help your community weight its options, our experts developed a list of 25 water and sewer related infrastructure improvement projects that may be eligible for ARPA relief funding.
1. ACCELERATE YOUR MUNICIPAL LEAD SERVICE LINE (LSL)
REPLACEMENT PROGRAM
Provides a community-wide benefit
“Recipients may use Fiscal Recovery Funds to invest in a broad range of projects that improve drinking water infrastructure, such as building or upgrading facilities and transmission, distribution, and storage systems, including replacement of lead service lines. Given the lifelong impacts of lead exposure for children, and the widespread nature of lead service lines, Treasury encourages recipients to consider projects to replace lead service lines.”
— Interim Final Rule, U.S. Department of the Treasury
2. REPAIR AND/OR REPLACE AGING SEWER MAIN
Especially beneficial in aging/economically depressed neighborhoods
3. LOOP WATER MAIN
Create system redundancy
Enhance hydraulics and fire flows
4. IDENTIFY AND MITIGATE SANITARY SEWER INFILTRATION AND
INFLOW
Manhole inspections: look for drainage issues, leaky covers, and joint leaks
Smoke testing
Dye testing
Pipe inspections
Replace manhole covers
Line manholes
5. IMPLEMENT AND/OR ACCELERATE A SEWER TELEVISING AND
CLEANING PROGRAM
Quick detection and repair of minor conditions prevents small problems from becoming major, costly problems
Regular mainline maintenance helps mitigate infiltration, which in turn relieves unnecessary strain on the treatment plant and prevents spikes in flow
Close observation allows for more accurate planning and budgeting for mainline repairs and replacements
6. INVEST IN SEWER FLOW METERING EQUIPMENT
Examine current sewer capacity
Improve ability for future community expansion and economic development
Identify problem sewers
7. COMPLETE SEWER AND WATER SYSTEM FIELD SURVEY
INVENTORIES
Accurately locate position of your assets
Internal manhole inspections and lidar scans
8. PERFORM PUMP STATION CONDITION ASSESSMENTS/UPGRADES
Lidar scanning cameras allow for quick, high-definition assessments
Upgrade pumps and controls
Add standby generator
9. FUND ENERGY EFFICIENT WWTF UPGRADES
Consider the long-term benefits of solar installation
Relief payment may cover capital costs related to energy efficient improvements
10. PREPARE WATER SYSTEM FOR ECONOMIC DEVELOPMENT
Will you need sewer and water extensions for new subdivisions and/or business parks?
Will you need additional structures to accommodate growth?
11. FUND PROJECTS THAT WOULD OTHERWISE BE FINANCED BY
LOANS WITH INTEREST
E.g., safe drinking or clean water fund loans
12. COMPLETE PROACTIVE GENERAL UTILITY REPAIRS AND/OR
REPLACEMENTS
Hydrants
Valves and valve boxes
Manholes
13. FUND WATER TOWER IMPROVEMENT PROJECTS
Repaint water towers that are currently painted lead-based paint
14. IMPLEMENT SUGGESTIONS FROM YOUR COMPLETED RISK &
RESILIENCE ASSESSMENT
Protect your water system from unpredictable threats and failure
Comply with America’s Water Infrastructure Act
15. FUND TMDL COMPLIANCE PROJECTS
IDDE programs
Identify and remedy illicit sanitary sewer connections to storm sewers
Erosion control programs
“Treasury encourages recipients to consider green infrastructure investments and projects to improve resilience to the effects of climate change. For example, more frequent and extreme precipitation events combined with construction and development trends have led to increased instances of storm water runoff, water pollution, and flooding. Green infrastructure projects that support storm water system resiliency could include rain gardens that provide water storage and filtration benefits, and green streets, where vegetation, soil, and engineered systems are combined to direct and filter rainwater from impervious surfaces.”
— Interim Final Rule, U.S. Department of the Treasury
16. FUND GREEN INFRASTRUCTURE PROJECTS
Rain gardens
Permeable pavement
Storm water ponds
OUR BEST RESOURCES FOR STORM WATER MANAGEMENT
17. FUND MS4 PERMIT COMPLIANCE PROJECTS
Mapping jurisdictional boundaries of your storm sewer system, outfalls, pipes, ditches, roads, and receiving waters
BMP maintenance
18. PAY FOR THE COSTS OF PFAS DISPOSAL AT WWTFS
Costs associated with transporting PFAS waste to appropriate disposal facilities
19. FUND CORROSION CONTROL STUDIES AND TREATMENT
Wisconsin DNR is requiring municipalities to conduct corrosion control studies with greater frequency
Treatment can be costly, this payment can help you stay ahead of the curve and address corrosion issues before a forced assessment
20. MAKE THE MOVE INTO A DIGITIZED ENVIRONMENT AND INVEST
IN A GIS TO BETTER MANAGE WATER/SEWER INFRASTRUCTURE
Know the location and condition of your assets
Prioritize infrastructure replacements
Make reporting easier and more efficient
21. USE TECHNOLOGY TO IDENTIFY AND ADDRESS THE GREATEST
WEAKNESSES IN YOUR COMMUNITY INFRASTRUCTURE
GIS technology allows you to perform an honest infrastructure assessment
How resilient is your current infrastructure?
What unpredictable potential events and/or hazards would have the biggest impact on your community?
“With respect to wastewater infrastructure, recipients may use Fiscal Recovery Funds to construct publicly owned treatment infrastructure, manage and treat storm water or subsurface drainage water, facilitate water reuse, and secure publicly owned treatment works, among other uses. Finally, consistent with the CWSRF and DWSRF, Fiscal Recovery Funds may be used for cybersecurity needs to protect water or sewer infrastructure, such as developing effective cybersecurity practices and measures at drinking water systems and publicly owned treatment works.”
— Interim Final Rule, U.S. Department of the Treasury
22. COMPLETE AN ADVANCED POTABLE WATER SYSTEM MODEL
Obtain important information about fire flows and system performance
Address water aging issues, establish flushing programs
23. DEVELOP A 3D STORM WATER FLOOD CONTROL AND/OR WATER
QUALITY MODEL
Easily visualize areas at risk for future flooding and prepare your community for rain events before they cause significant destruction
Treat and control TSS, phosphorus, and other constituents
24. UPGRADE YOUR WWTF TECH AND SCADA EQUIPMENT
Replace old control panels
New equipment will also help utilities complete Risk & Resilience Assessments and Emergency Response Plans, as required for compliance with America’s Water Infrastructure Act
25. MOVE WWTF FROM RADIO TO CELLULAR TECHNOLOGY
Cellular can significantly improve coverage area, especially for facilities in low elevations with limited access to radio
Can be implemented on a site-by-site basis, used as a supplement to radio.
LEARN MORE
Our sewer and water experts have decades of experience helping Wisconsin municipalities successfully plan, design, and permit projects with condensed timeframes and limited budgets. We also understand that your water/sewer infrastructure needs are as unique as the needs of your residents, and there is no one-size-fits-all solution for how to best allocate this new funding. If you’d like to learn more about how our experts can help you plan water and/or sewer projects that will make a long-lasting impact in your community, please contact us today.
About the Author
RYAN T. AMTMANN, P.E.
VICE PRESIDENT
Ryan joined the Ruekert & Mielke, Inc. (R/M) team in 2007. He has worked as a Project Manager and Project Engineer on municipal projects, including wastewater collection and conveyance system design, storm water management and facility design, water main design, site development, development review and general municipal consultation and planning.