Eligibility for the Clean Watersheds Needs Survey

Eligible Participants

The following entities are eligible to participate in the 2022 Clean Watersheds Needs Survey:

  • All municipalities
  • Local Health Departments, Soil and Water Conservation Districts and Municipal Planning Departments
  • State and Federal Agencies
  • Not-for-Profit organization with water quality issues
  • Engineering firms, technical assistance organizations and professional organizations

Needs Consideration for Native Lands

The Indian Health Service (IHS) conducts a survey and prepares a Report to Congress annually under Public Law 86-121 on the capital investment needs for wastewater infrastructure on tribal reservations and in Alaskan Native Villages. Those needs are based on the Sanitation Deficiency System (SDS) within the IHS Sanitation Tracking and Reporting System (STARS). For more information about the IHS data collection and the SDS, refer to the IHS website.

So as not to duplicate this effort, the CWNS does not include wastewater treatment or decentralized treatment projects planned on Native American land. However, because IHS does not collect information about needs associated with stormwater and NPS control, those needs can be included in the CWNS.

Eligible Projects

For a project to be included in the 2022 CWNS, it must be:

  • CWSRF eligible. A CWSRF eligible project is a solution to a water quality problem that is eligible for funding according to national CWSRF eligibility criteria.
    • Note that flood control structures or stormwater projects that do not have water quality benefits are not eligible, as defined in the CWSRF guidance.
    • Note that planning activities that have a reasonable prospect of resulting in a capital project are eligible.
    • CWSRF eligibility for wastewater and stormwater facilities is generally limited to publicly owned facilities; however, NPS and decentralized facilities can be privately owned. Pilot projects for increased resilience of treatment works and energy or water conservation projects can also be privately owned.
  • Unfunded. For the 2022 survey, a project is considered funded—and therefore not a need—if by January 1, 2022, construction has started or external funds (e.g., a grant or executed loan) are committed to the project, even if construction has not yet begun.
    • Projects scheduled to begin construction prior to January 1, 2022, are considered “funded” and therefore may not be included in the CWNS, as they are no longer considered to be needs. If only part of the project is funded as of January 1, 2022, that portion is excluded, but the remaining unfunded costs or unfunded phases may be included.
  • Within the survey period. The CWNS captures costs associated with capital investment projects that have not begun construction before January 1, 2022, and that are planned to be completed by December 31, 2041; it cannot include costs that fall outside this period.

Unallowable Costs

The CWNS does not allow non-capital costs, including:

  • Costs for ongoing operations and maintenance (O&M).
  • Payroll or fringe benefits for typical facility operations.

In some cases, documentation of need for an eligible project may include costs that are not CWSRF eligible. These costs cannot be reported as needs in the CWNS and will be deducted from the total project cost. Examples include:

  • Land acquisition that is not integral to an eligible project. An example of eligible acquisition is land purchased for the location of the project or for siting a treatment process as part of the eligible project. An example of ineligible acquisition would be land purchased to be used as a recreational area adjacent to the project.
  • Road improvements that are not integral to an eligible project.
  • Abandonment/demolition as a stand-alone project with no water quality benefit. However, demolition of infrastructure (such as a treatment plant) that is an integral part of an eligible project (such as a treatment plant replacement) is eligible. Similarly, replacement of gray infrastructure with green infrastructure including purchase and demolition costs is eligible.