Understanding State-by-State Differences in IUPs and Project Lists: Findings from EPIC’s DWSRF Funding Tracker
By: Lauren Kwan and Danielle Goshen
Intended Use Plans (IUPs) play an essential role in directing how Drinking Water State Revolving Fund (DWSRF) dollars reach communities. Yet anyone who has worked across multiple states knows that IUPs—and the project lists contained within them—can look very different depending on which state and funding cycle you are reviewing.
As part of EPIC’s multi-state DWSRF Funding Tracker, we’ve been reviewing DWSRF IUPs across 15 states to analyze trends and outcomes across programs. This work has highlighted several differences in how states assemble, publish, update, and maintain IUPs and project lists. These differences are not merely cosmetic. They shape how transparent SRF programs are, how easily communities can navigate the funding pipeline, and how accurately funding trends can be analyzed across states and over time. The infusion of supplemental funds in the SRFs from the Infrastructure Investment and Jobs Act (IIJA) has heightened public interest in tracking these funds.
Below, we summarize nine key lessons from our comprehensive explainer on Differences in How States Organize Their Intended Use Plans (IUPs) and Project Lists, and discuss why these variations matter for communities, policymakers, and analysts alike.
1. States Differ in Number of IUPs Published Covering the Federal Capitalization Grant(s) Drawn Down During a Given Funding Cycle
Some states issue a single comprehensive IUP that covers all federal capitalization grants (Base, IIJA General Supplemental, IIJA Lead Service Line Replacement, and IIJA Emerging Contaminants) and other sources of funds (e.g., leveraged funds and revolving funds). Others publish multiple IUPs to address supplemental federal capitalization grants separately.
2. States Must Publish a Draft and Final IUP, and Can Also Publish Amendments
All states must issue a draft and final IUP, but their approach to amendments varies significantly. Some publish amendments as standalone documents, and others replace the original IUP entirely. Amendments often reflect updated project lists, new funding, or changes in state policies. This variation can make tracking changes challenging.
3. States Call their Comprehensive and Fundable Lists by Different Names
Federal regulations require states to include with their IUP a comprehensive list of projects—often referred to as a Project Priority List (PPL)—that assigns priority rankings to all eligible projects for which an applicant or potential applicant has expressed interest in receiving DWSRF assistance. States are also required to publish a fundable projects list (sometimes called a funding list), which identifies projects that have cleared the first hurdle toward receiving assistance from funds available during the current funding cycle.
To analyze a state’s program, a first step is to identify the comprehensive list and the fundable list. What one state calls a “Project Priority List” may be a comprehensive list. Another may use that same term for its fundable list. States often use unique terms such as “Multi-Year List,” “Priority Ranking List,” or “Intended Funding List.”
4. States Differentiate Their Comprehensive and Fundable Lists in Different Ways
Some states publish two distinct lists to delineate its comprehensive and fundable lists. Others distinguish them with a funding line, separate tables, or expected funding amounts. Some publish supplemental lists that provide additional detail (for example, in relation to disadvantaged community status) but do not function as standalone lists of projects. These design choices affect how easily readers can interpret anticipated funding decisions.
5. States Don’t Always Provide Both a Comprehensive List and a Fundable List
Although federal rules require states to publish both a comprehensive and fundable list, not all states make both (or sometimes either) available. This can make it difficult to assess program demand or to evaluate which projects are expected to move forward.
6. States Contain Different Information on Their Comprehensive and Fundable Lists
Because federal regulatory requirements specify only minimal information for comprehensive and fundable lists, states vary widely in the details they provide. Some states include extensive project-level information, while others provide only what is strictly required. Terminology also differs significantly across states, which can make comparisons challenging. In addition, just as states may issue separate IUPs for different funding sources (see Lesson 1), they may also present general, LSLR, and EC projects within a single table or across multiple tables in the same IUP.
7. The Hurdles Applicants Face on the Path Towards Signing Funding Agreements Occur at Different Points in the Process
In some states, projects on the fundable list have already submitted full applications, so only ready-to-proceed projects appear there. In others, the fundable list is built from preliminary intent-to-apply forms, and only later are full applications collected and readiness assessed. As a result, many initially high-ranking projects may be bypassed if they cannot demonstrate readiness once applications are reviewed, while lower-ranking but shovel-ready projects move forward instead.
Understanding what information a state uses to construct its project lists is therefore essential. When we refer to projects “on the fundable list” in our analyses, we mean the point at which a state moves projects from the comprehensive list to the fundable list. However, what this stage represents for applicants varies significantly across states—and has major implications for how closely a fundable list is expected to reflect final project awards.
8. States Have Different Policies for Archiving IUPs on Their Websites
One of our final takeaways from reviewing state IUPs is that archiving practices matter. Some states, such as Mississippi, retain IUPs online for only one or two funding cycles. When older IUPs are not preserved, it becomes extremely difficult to analyze year-over-year trends in funding decisions, principal forgiveness distribution, or program design changes—often requiring researchers to download and independently archive documents just to conduct longitudinal analysis. We encourage all states to systematically archive past IUPs and related materials to ensure long-term accessibility, accountability, and evidence-based policymaking.
9. States Differ in How Machine-Readable and Downloadable Their Project Lists Are
States also differ significantly in how machine-readable and downloadable their project lists are. Many states publish comprehensive and fundable lists only as static PDFs, and this format can limit the ability of stakeholders to analyze funding trends, assess impacts to communities, or compare outcomes across funding cycles. In some cases, lists are formatted in ways that further constrain usability, making it difficult to scrape, standardize, or systematically analyze the data. By contrast, when states provide clean tables or downloadable spreadsheets (e.g., Excel or CSV files), project-level data can be more easily sorted, filtered, and evaluated over time. Improving the accessibility and structure of published project lists is a low-cost administrative step that can meaningfully enhance transparency, reduce administrative burden, and support more evidence-based decision-making within SRF programs.
How EPIC’s Funding Tracker Helps
IUPs are more than compliance documents—they are the first public signal of how state SRF policies translate into funding decisions. Our review shows that states vary widely in how they label, structure, update, and publish comprehensive and fundable project lists. These practices affect transparency, accessibility, and how reliably trends can be compared across states and funding cycles. EPIC’s DWSRF Funding Tracker helps bridge these gaps by standardizing project- and financial-level data across 15 focus states, making differences easier to interpret. Many improvements—like clearly identifying both lists, maintaining archives, and publishing machine-readable project tables—are low-cost steps that can meaningfully strengthen accountability and public understanding of how DWSRF dollars are allocated.