Final Intended Use Plan for the New York State Drinking Water State Revolving Fund

Attachment VII: Response to Comments on the Draft Intended Use Plan

The following response to comments was prepared to address the public's comments on the Drinking Water State Revolving Fund's draft Intended Use Plan that was issued on June 27, 2007. The public comment period began on June 27, 2007 and ended on August 10, 2007. The public was also invited to comment on the draft IUP at a hearing held in Albany, New York on July 26, 2007. In addition to the comments addressed herein, a number of project specific comments were received and addressed on an individual basis. Specific changes made to the project priority lists included in the draft IUP are provided in Appendix 1.

Comment:

The DWSRF program should consider awarding additional scoring points or using the special activities set-aside to address the financial needs of certain disadvantaged communities in the State.

Response:

The DOH conducts an annual review of the DWSRF scoring criteria to determine whether a change to the scoring criteria is warranted. We will consider awarding additional scoring points to disadvantaged communities as part of our next review. As for the special activities set-aside, we are not proposing to use this set-aside. Any use of the special activities set-aside in the near future will place an undue burden on the financing capabilities of the overall program to address the significant need that currently exists.

Comment:

Additional or supplemental grants are needed. An example was cited where a community was unable to access their entire grant award.

Response:

The DWSRF program is allowed by federal statute to utilize up to 30% of their annual capitalization grant to provide grants to eligible disadvantaged communities. Table 3 of the IUP lists the amount of each capitalization grant and the 30% allotment that was taken to provide grant monies to disadvantaged communities. As you can see, the DWSRF program is taking the maximum grant allotment on an annual basis. Regarding the community's access to its entire grant award, the project financing agreement into which the community entered for DWSRF financing provided the necessary details to address the cited example.

Comment:

The Target Service Charge formula found in Section 7.4 of the Intended Use Plan is not properly illustrated as a mathematical solution.

Response:

Brackets were added to the formula to differentiate the hierarchy of the functions.