How States’ Disadvantaged Community Definitions Can Prioritize Access to SRFs for Under-Resourced Communities

waterresources
Written By Danielle Goshen

By Danielle Goshen, Janet Pritchard, and Lauren Kwan

The challenge of ensuring safe, affordable, and resilient water infrastructure in the United States is formidable, particularly for historically under-resourced communities. Addressing these challenges requires nuanced and strategic policy decisions at the state level. The influx of funds to State Revolving Fund (SRF) programs from the the Infrastructure Investment and Jobs Act (IIJA), including increased additional subsidies directed to state-defined Disadvantaged Communities (DACs), elevates these issues and is motivating states to evaluate and refine their SRF policies, while also motivating advocates and other interested parties to weigh in.

This brief, through a detailed analysis of the diverse approaches taken by the 50 states through analyzing Intended Use Plans (IUPs), reveals varied methodologies, and offers no one-size-fits-all solution. However, through this analysis, several key recommendations stand out. To ensure states’ allocation of resources reaches under-resourced communities, we recommend the following state policies around defining DACs:

  • Determining the Factors Used to Define DAC Eligibility

    • Ensure DAC factors are relevant to the state’s objectives should clearly differentiate levels of disadvantage to prioritize those most in need.

    • Use a set of comprehensive criteria to define DACs

    • Specify appropriate  thresholds to determine which communities qualify as disadvantaged

    • Develop DAC definitions that are easy to understand and apply, using publicly accessible data and tools

    • Customize DAC definitions to address specific community and project needs

    • Periodically review and adapt definitions to align with evolving needs and circumstances

  • Structuring the DAC Definition to Enable Balanced Consideration of Multiple Factors and Ranking of DACs on the Basis of Relative Need

    • Adopt scaled definitions

  • Determining the Geographic Scope Used to Apply DAC Factors and Thresholds

    • Consider project service area as the geographic scope

Danielle Goshen
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