Planning Phase

Facilities Plan

A Facilities Plan must demonstrate the need for a proposed action, evaluate viable alternatives, and select the most cost-effective, implementable, and environmentally sound solution that will meet the public needs over the design life of the facility.  A Facilities Plan must include an evaluation of the current and future population of the facilities planning area and their water/wastewater needs.  It must also present a comprehensive evaluation of the current environment in the planning and project areas, potential impacts to the environment caused by the construction of the proposed project, and actions necessary to prevent potential negative environmental impacts.  A Facilities Plan must also demonstrate and document public participation in the decision-making process.  Four copies of a Facilities Plan must be submitted to the State Revolving Fund Loan Program for review and approval prior to recommending the Clean Water/Drinking Water State Revolving Fund (SRF) loan award to the Tennessee Local Development Authority.

A Facilities Plan should contain an Executive Summary, detailed descriptions of the proposed project’s purpose and need, existing and future conditions; development of alternatives; an evaluation of the principal alternative(s); and the selected plan.  The text of a Facilities Plan should be augmented with a topographic map of the planning and project areas and any other maps and figures necessary to graphically convey and support the technical and environmental information presented and the alternative(s) selected.  Conclusions and recommendations provided in the Facilities Plan must be supported by the technical and environmental information presented therein.

The environmental information presented in a Facilities Plan must be a comprehensive evaluation of the current environment in the planning and project areas, the potential impacts of construction on the environment, and the actions necessary to prevent potential negative environmental impacts. The SRF Loan Program´s technical staff reviews the environmental information and pays particular attention to the utilization of that environmental information in the development of alternatives and the selection of the most cost-effective alternative.

Subsequent to the successful completion of the technical and environmental reviews of the Facilities Plan, the Plan of Operation, and the public participation process, either a Categorical Exclusion (CE), a Finding of No Significant Impact (FNSI) including an Environmental Assessment, or an Environmental Impact Statement is issued for public and agency review and comment. The review process is complete only after comments and additional information have been satisfactorily addressed and supplied.

Environmental Reviews

The technical staff of the State Revolving Fund Loan Program (SRF Loan Program) completes an extensive environmental and technical review of every proposed Clean Water State Revolving Fund (CWSRF) project. The environmental and technical information that is prepared by the CWSRF loan applicant´s consulting engineer and presented in the Facilities Plan is reviewed to ensure compliance with various, applicable federal and state requirements.

The SRF Loan Program´s technical staff coordinates an Interdisciplinary Environmental Review (IER) during the early stages of the Planning Phase. The IER is presented to fourteen State and Federal environmental agencies for review and comment and consists of a detailed, concise project description accompanied by a copy of a 7.5-minute USGS topographic quadrangle map delineating the proposed project. IER agencies contacted include the following:

  • Tennessee Department of Agriculture
  • Tennessee Department of Economic and Community Development
  • Tennessee Department of Transportation
  • Tennessee Division of Air Pollution Control
  • Tennessee Division of Archaeology
  • Tennessee Division of Natural Areas
  • Tennessee Division of Solid Waste Management
  • Tennessee Division of Water Resources
  • Tennessee Historical Commission
  • Tennessee Wildlife Resources Agency
  • US Army Corps of Engineers
  • US Fish and Wildlife Service

Comments, if any, that are received from the reviewing agencies generally necessitate special CWSRF loan conditions requiring the loan recipient to mitigate the respective agency´s concerns subsequent to award of the CWSRF loan and prior to the approval of the Plans and Specifications for the proposed project.

Environmental information is an integral part of every Facilities Plan. The environmental information presented in a Facilities Plan must be a comprehensive evaluation of the current environment in the planning and project areas, the potential impacts of construction on the environment, and the actions necessary to prevent potential negative environmental impacts. The SRF Loan Program´s technical staff reviews the environmental information and pays particular attention to the utilization of that environmental information in the development of alternatives and the selection of the most cost-effective alternative.

Subsequent to the successful completion of the technical and environmental reviews of the Facilities Plan, the Plan of Operation, and the public participation process, either a Categorical Exclusion (CE), a Finding of No Significant Impact (FNSI) including an Environmental Assessment, or an Environmental Impact Statement is issued for public and agency review and comment. The review process is complete only after comments and additional information have been satisfactorily addressed and supplied.

Plan of Operation (Clean Water SRF projects only)

Tennessee´s State Revolving Fund Rules, Chapter 1200-22-6, require that Clean Water State Revolving Fund (CWSRF) loans be made only to local governments and utility districts that provide a written certification of their commitment to comply with the Plan of Operation that has been approved by the Department of Environment and Conservation. The Plan of Operation addresses the issues of allotment and allocation of personnel and resources in accordance with a timetable/schedule for adherence to the pertinent activities addressed in the Plan. The technical staff of the State Revolving Fund (SRF) Loan Program reviews the Plan of Operation in order to ensure that it exhibits a descriptive and chronological schedule reflective of a comprehensive evaluation/analysis of the essential activities to be undertaken during the construction, start-up, and Performance Certification periods. These activities include the development and implementation of staffing and training requirements including the quality of, compensation for, and number of facility personnel employed by the government or utility district for the lifetime of the loan, recordkeeping, reporting, laboratory controls, process controls and start-up, safety, the creation and implementation of an Emergency Operating Plan, maintenance management, the creation of and adherence to an Operation and Maintenance (O&M) Manual, and budgetary considerations.

The following PDF document is a sample Plan of Operation. The intent of the sample plan is to suggest a useful format and provide a framework to ensure that all potential needs have been addressed. This sample Plan of Operation is not intended as a rigid guide or as a replacement for an O & M Manual. It is still the responsibility of the facility´s owner and designated representatives to clearly identify the pertinent, essential items for a successful start-up and continued successful operation of their wastewater facility. The size, complexity, type of facility, and other factors will influence the extent of information required in a new or amended Plan of Operation. At a minimum, each of the areas in this sample Plan of Operation must be considered in the submitted Plan of Operation.

Public Participation Requirements

A Public Meeting must be held to inform the public of the salient aspects of the planned project and to provide interested parties with an opportunity to comment. The Public Meeting must be advertised at least 14 days prior to the meeting date in order to maximize public participation. Using a minimum of one of the following means, the advertisement must be distributed by being published in a local newspaper, posted at banks, grocers, post offices, public library, city hall, etc., publicized through local television and/or radio stations, or inserted with monthly sewer bills. The advertisement must include the meeting date, time, and location. In addition, the advertisement must specify the amount of the proposed loan and state that the loan will impact the monthly sewer fees. An example Public Notice is provided below. The meeting must be scheduled on weekday evenings after 6:00 p.m. or on weekends in order to provide the public with the maximum attendance opportunity.

Discussion topics at the public meeting must include, but are not limited to, a complete description of the project, the project schedule, short-term impact verses long-term benefits, and the project´s impact on sewer user fees regarding the repayment of the CWSRF loan as well as funding depreciation. Submissions to the SRF Loan Program must include a copy of the published advertisement, a Publisher´s affidavit from the newspaper, radio station, or television, as applicable, an account of the meeting (transcript, audio, or video recording, etc.), public meeting attendance sheet, and a brief summary of the public meeting discussion.

Public Meeting Information and Guidance