Hello,

This is a very bad idea.  What this is really saying is that many 
communities are not applying for CWSRF low interest loans to upgrade 
failing and inadequate wastewater treatment plants.  And why should 
they?  So far there has been no significant pressure put on them that I can 
see to meet the requirements of the more protective water quality standards 
approved in January 2006.

The impact of last years improved standards could require more than 350 
communities to improve their wastewater treatment capabilities in order to 
properly protect for recreation and aquatic life in rivers and streams. We 
are faced with more than 200 Use Attainability Analyses potentially being 
presented to the EPC in April or May.  Probably 90% + of them should uphold 
the "fishable/swimmable" status given to the rivers and streams last 
year.  If not, there is something wrong with the UAA process and we will 
have to step in to fix it.

If the whole water quality standards upgrade / UAA process represents 
anything more than a paper exercise and a shell game, hundreds of 
communities will need to take advantage of the CWSRF loan fund over the 
next few years to improve their wastewater treatment plants.  In my 
opinion, transferring some of the CWSRF money to the Drinking Water fund is 
a very bad idea.

Steve Veysey

  12:43 PM 3/20/2007, you wrote:

>Iowa Department of Natural Resources
>
>Iowa Finance Authority
>
>PUBLIC MEETING AGENDA
>
>
>
>NOTICE TO PARTIES INTERESTED IN LOW INTEREST LOANS FOR
>
>WATER SUPPLY INFRASTRUCTURE PROJECTS AND
>
>WATER POLLUTION CONTROL AND ABATEMENT PROJECTS
>
>
>
>
>
>NOTICE OF PUBLIC HEARING
>
>Updates to the FY 2007 Intended Use Plans
>
>for the administration of the Drinking Water State Revolving Fund
>
>and the Clean Water State Revolving Fund
>
>
>
>
>
>The Iowa Department of Natural Resources and the Iowa Finance Authority 
>will hold a public meeting on April 4, 2007, 9:30 a.m., at the DNR Water 
>Supply office, 401 SW 7th Street, Suite M, Des Moines, IA  50309. Comments 
>will be invited on a revision to the CWSRF and DWSRF Intended Use Plans to 
>allow temporary investment of CWSRF monies in the DWSRF.  Updates will be 
>presented to the Environmental Protection Commission in May 2007.
>
>
>
>Oral comments may be presented at the meetings. Requests for copies of the 
>IUP updates and written comments may be directed to Patti Cale-Finnegan, 
>State Revolving Fund Coordinator, Water Quality Bureau, Iowa Department of 
>Natural Resources, 401 SW 7th Street, Des Moines, IA  50309 (Telephone 
>515/725-0498 or FAX 515/725-0348) or at 
><mailto:[log in to unmask]>[log in to unmask]
>
>
>
>
>
>Iowa Department of Natural Resources
>
>Environmental Protection Commission
>
>
>
>
>
>ITEM
>
>
>
> 
>DECISION
>
>
>
>TOPIC
>
>Clean Water and Drinking Water State Revolving Loan Funds – 2007 Intended 
>Use Plan Updates to Allow Cross-Program Investment
>
>
>
>
>
>
>
>Approval will be sought from the Environmental Protection Commission of 
>changes to the Clean Water State Revolving Fund (CWSRF) and Drinking Water 
>State Revolving Fund (DWSRF Intended Use Plans to allow cross-program 
>investment.  A proposal has been sent to the U.S. Environmental Protection 
>Agency.  The primary purpose is to allow use of uncommitted CWSRF monies 
>to delay implementation of a bond issue in the DWSRF program until it is 
>more economically beneficial.  The Iowa Finance Authority estimates that 
>the estimated savings in cost of issuance and interest expense of doing 
>one large issue in the fall of 2008 instead of two smaller bond issues is 
>approximately $300,000.
>
>
>
>The language below is proposed as additions to the CWSRF and DWSRF 
>Intended Use Plans:
>
>
>
>With EPA approval, IFA proposes to temporarily invest CWSRF monies in the 
>DWSRF in May or June 2007.  The investment would be short-term in 
>nature.  The investment plus interest would be repaid within two 
>years.  Both the CWSRF and the DWSRF charge 3% interest on their 
>loans.  The investment from the CWSRF will earn the same rate as it would 
>have earned had it been used for wastewater loans.  An investment contract 
>formally detailing the terms between the two programs will be developed 
>and executed.
>
>
>
>Currently, the CWSRF has a balance of past loan repayments that are not 
>pledged to any outstanding bond issues.  By using these funds to invest, 
>there are no concerns with any outstanding bond documents. The maximum 
>amount of investment from the CWSRF to the DWSRF will be $25 
>million.  This investment will provide a temporary source of capital to 
>fund DWSRF loans until a bond issue can be completed in FY 2008.
>
>
>
>
>
>Patti Cale-Finnegan
>
>Water Quality Bureau
>
>
>
>
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