Utilities must receive Commission approval for SDWBA and Drinking Water State Revolving Fund loans because these loans are repaid by the utility through a surcharge to ratepayers. For any portion of plant that is paid for by non-grant funds, this same procedure shall be followed. The utility should seek Commission approval through the application process, either in its general rate case or separately.
For plant wholly funded by a grant, as well as for the partially grant-funded portion of a plant, we should require notification to the Director of the Water Division when the utility signs a letter of commitment with the funding agency administering the grant and again upon completing the funding agreement execution with the funding agency.
In addition, each utility that receives grant funds shall so state in its Annual Report to the Commission, with the detail of the type and location of the plant constructed.