Background

The approved Federal Budget for the FFY 2010 and FFY2011 Clean Water State Revolving Fund (CWSRF or SRF) program includes provisions to promote ‘green’ technologies and requires States to establish a Green Project Reserve (GPR). The GPR provision generally requires States to reserve not less than 20% of the annual federal allocation for CWSRF capitalization grants to address green infrastructure, water or energy efficiency improvements, or other environmentally innovative activities.

Projects meeting GPR criteria are subject to all SRF program requirements. Criteria for determining CWSRF GPR eligibility can be found in GPR Guidance Document (pdf, 246kb). Projects clearly eligible for GPR are known as ‘categorically eligible’ projects. A list of ‘categorically eligible’ projects can be found in the GPR guidance document mentioned above. However, some traditional projects that are not determined to be ‘categorically eligible’ may have benefits that can be counted toward the 20% Green Project requirement. For traditional projects (or portions thereof) to be counted towards the 20% GPR requirement, the project files must contain documentation that satisfies the ‘business case’ criteria established by USEPA which includes projections of identifiable and measurable benefits associated with the use of ‘green’ technologies in the construction of the project.

GPR Business Case:

A ‘business case’ needs to provide a well documented justification for a project to be considered a GPR project. The required documentation could be a simple memo but must indicate the basis on which this project was judged to qualify to be counted toward the 20% requirement. Such a memo would typically include direct reference to a preliminary engineering or other planning document that makes clear that the basis upon which the project (or portion) was undertaken included identifiable and substantial benefits qualifying for the Green Project Reserve. For the further detail on how to develop a ‘business case’, see Part A, Section 5 of the GPR Guidance Document mentioned above. EPA requires States to post the approved business cases on the CWSRF program website so that they are available to the public.

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