WIFIA Engineering Feasibility Review Support

Under the 2014 Water Infrastructure Finance and Innovation Act, Congress established a federal credit program to accelerate public and private sector investment in our nation’s water infrastructure. Administered by the U.S. Environmental Protection Agency, the WIFIA program provides long-term, low-cost supplemental loans for regionally and nationally significant water and wastewater infrastructure projects. Prospective borrowers submit a letter of interest to EPA for evaluation and then, if invited to do so, a formal application. EPA sought ERG’s help in establishing a reliable, consistent process for conducting screening-level environmental reviews of the letters of interest. These reviews needed to follow an aggressive schedule to meet deadlines.

ERG rapidly assembled a team of reviewers and developed checklists and guidance to ensure consistent environmental reviews. These quick-turnaround reviews, which we conducted for more than 40 projects, included recommending the appropriate level of National Environmental Policy Act review for each project (categorical exclusion, Environmental Assessment, or Environmental Impact Statement) and assessing the applicability of numerous federal environmental cross-cutting authorities. We also assigned relative risk scores for each project, based on the applicant’s demonstrated ability to address the identified NEPA and cross-cutting authority requirements. Additionally, we conducted more detailed environmental reviews for projects selected to receive WIFIA financial support. For these reviews, we evaluated the applicability of federal cross-cutting authorities, the project’s potential impacts, and the status of coordination and consultations with other agencies. We documented the results of these findings in memorandums to EPA.