These comments reflect the BlueGreen Alliance’s shared goals and partner goals to ensure that the most State Revolving Fund support goes to areas with the greatest lead burden and overall disadvantage, and increasing capacity and community engagement as necessary to these ends and as goods in themselves. Thus, at the outset, we recognize and thank Ohio’s Environmental Protection Agency (EPA) for taking significant steps in recent years to better distribute the Drinking Water Assistance Fund (DWAF) funding to disadvantaged communities within the state. We similarly appreciate EPA recognizing the serious public health threat posed by lead in drinking water, and revising its DWAF administration to help deliver more critical funding to communities committed to getting the lead out. Based on an initial review of the Projects Eligible for Lead Service Line Funding, it appears that these shifts have helped direct significant levels of principal forgiveness and zero-interest loans to communities with the state’s greatest lead burdens and need for financial assistance to abate this health hazard. In these comments, we focus on how Ohio EPA can further enhance transparency and accessibility regarding how it is distributing and maintaining the DWAF, as well as propose revisions that may help target more assistance to disadvantaged communities and ensure that communities are proceeding to finalized agreements for lead service line
replacement.

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