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About More Protection, Less Process

More Protection, Less Process is an initiative to alleviate the impact of increased federal requirements on loans from the Clean Water and Drinking Water State Revolving Funds (SRFs). The increase in federal requirements over the last decade has shifted more and more money from construction to compliance. The burdensome paperwork and compliance procedures have also deterred potential borrowers from undertaking much needed water infrastructure projects. 
Read the policy recommendations

Growth in Federal Requirements

Since 2009, a myriad of new federal requirements have been added to SRF loans making management of the program more complex and compliance more costly. According to a 2018 survey of SRF directors, the cumulative impact of compliance with federal requirements is the number one challenge to greater investment in water infrastructure.

Borrowers of both SRFs must comply with: 

  • Davis Bacon which requires mechanics and laborers on water infrastructure projects that receive federal funding to be paid hourly wages determined by the U.S. Department of Labor.

  • American Iron & Steel which requires materials used in water infrastructure projects to be made in the United States.

Borrowers of both SRFs that receive loans funded by the annual federal capitalization grant (also referred to as "equivalency" projects) must:

  • Be reported in the Federal Funding and Accountability and Transparency Act (FFATA).

  • Use the federal procurement process for selecting architects and engineers.


Borrowers of the Clean Water SRF must:

  • Conduct a cost analysis of techniques and technologies to conserve water and energy.

  • Develop a fiscal sustainability plan.

Additional requirements on federally funded projects:

  • Single Audit Act (OMB a-133) 

  • Environmental Crosscutters (federal requirements that "cut across" federal funding programs)

  • Disadvantaged Business Enterprise Procurement Process

  • Public Awareness Enhancement (Signage)

  • FFATA Executive Compensation Reporting

Clean Water and Drinking Water State Revolving Funds 

The Clean Water and Drinking Water State Revolving Funds are the nation's premier program for providing communities with low cost, affordable financing for water infrastructure that protects public health and the environment. 

Council of Infrastructure Financing Authorities (CIFA)

The initiative was launched by the Council of Infrastructure Financing Authorities (CIFA) whose members are the state agencies that manage the Clean Water and Drinking Water State Revolving Funds. 


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