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Environmental Loans (EL) Cost & Effectiveness Certification

Federal requirements for Cost and Effectiveness Certification

Clean Water Act amendments passed in June 2014 added a number of new federal requirements to the Clean Water Fund Program (CWFP). The last of these requirements being implemented for CWFP applicants is the requirement for Cost and Effectiveness Certification.

Starting with applications submitted on or after October 1, 2015, all assistance recipients must certify that they:

  1. have studied and evaluated the cost and effectiveness of the processes, materials, techniques, and technologies for carrying out the proposed project or activity; and
  2. have selected, to the maximum extent practicable, a project or activity that maximizes the potential for efficient water use, reuse, recapture, and conservation, and energy conservation, taking into account:
    • the cost of construction of the project or activity;
    • the cost of operating and maintaining the project or activity over the life of the project or activity; and
    • the cost of replacing the project or activity.

Certification form

CWFP applicants must submit the Cost and Effectiveness Certification form at the time they submit their CWFP Financial Assistance Application (Wastewater Treatment Projects form 8700-203 or Stormwater/Urban Runoff Projects form 8700-313). Note: The certification must be signed by the project design engineer and the municipality's authorized representative.

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Isn't this type of analysis already required as part of facilities planning?

Yes, it is, though depending on the type of project, an evaluation of energy and water conservation may not be required under chapter NR 110. In order to meet the new federal requirements for cost and effectiveness, all of the items listed above must be considered.

The State requires a cost-effectiveness analysis as part of facilities planning under ch. NR 110, Wis. Adm. Code. Municipalities are required to implement the most cost-effective alternative. Sewage treatment facilities projects are further required to include as part of the cost-effectiveness analysis an analysis of innovative and alternative treatment processes and techniques that reclaim and reuse water, productively recycle wastewater constituents, eliminate the discharge of pollutants, or recover energy. In addition, sewage treatment facilities projects are required to include an analysis of the primary energy requirements (operational energy inputs) for each system considered. The alternative selected shall propose adoption of measures to reduce energy consumption or to increase energy recovery as long as such measures are cost-effective.

All projects financed through the CWFP are required to submit a facilities plan for review and approval, even projects such as basic sewer rehabilitation that are normally not considered reviewable projects and would otherwise not require an approval. The "Fast Track" approval process for sewer projects should not be utilized if you plan to seek CWFP funding.

Information on Facilities Planning requirements can be found on DNR's website:

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Aren't the Fiscal Sustainability Plans (FSPs) also required to certify that water and energy conservation were evaluated?

Yes, Fiscal Sustainability Plans (FSPs) are required to include a certification that water and energy conservation have been evaluated and are being implemented. The FSP evaluation and certification applies to the entire treatment system though, while the Cost and Effectiveness Certification is specific to the project for which the applicant is currently seeking funding.

Is any further guidance available?

Contact information
Direct questions about Cost and Effectiveness to:
Becky Scott
For information about the CWFP, contact:
Lisa Bushby
Clean Water Fund Program (CWFP) coordinator

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Last revised: Thursday June 29 2017