EPIC Comments on Texas Draft SFY 2026 Drinking Water State Revolving Fund (DWSRF) Lead Service Line Replacement (LSLR) Program

waterpublic comments
Written By Danielle Goshen

On behalf of the Environmental Policy Innovation Center (EPIC), I am grateful for the opportunity to submit comments on the state’s Draft SFY 2026 Drinking Water State Revolving Fund (DWSRF) Lead Service Line Replacement (LSLR) program. The Texas Water Development Board (TWDB) has undergone immense growth in policy and financial responsibilities over the last decade. This Draft Intended Use Plan (IUP) covers capitalization grant funds planned to be allocated to Texas from FFY2025 appropriations for Lead Service Line Replacements (LSLR) in the amount of $77,961,000. Our comments provide the following recommendations:

  • Reduce administrative burden by allowing cross-program consideration of lead projects on the general IUP lists for LSLR funds

  • Use additional set-aside funding for LSLR inventories and to speed-up LSLR project pipeline

  • Revise disadvantaged community policies

  • Revise project rating criteria

These comments draw on findings from two complementary EPIC initiatives: (1) the Texas Community Water System Prioritization Tool and (2) the DWSRF Funding Tracker.

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Danielle Goshen

Danielle is the Senior Water Infrastructure Policy Analyst at EPIC. Prior to joining EPIC in 2024, Danielle worked on National Wildlife Federation's Texas Coast and Water Program as their Policy Specialist/Counsel where she collaborated with government, industry, and NGO stakeholders to improve water policy across Texas. Prior to her work at NWF, Danielle was the Water Policy Specialist at Galveston Bay Foundation. She attended the University of Toronto for her Honours Bachelor's degrees in Environmental Geography and Environmental Studies, with a minor in Geographic Information Studies. Danielle later earned her J.D. at the University of Georgia School of Law, where she was president of the Environmental Law Association. During her time at Georgia Law, Danielle interned at the Environmental Protection Agency’s Region 4 office and served as a Georgia Sea Grant Legal Fellow working on coastal resiliency policy.

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Understanding State-by-State Differences in IUPs and Project Lists: Findings from EPIC’s DWSRF Funding Tracker