
Division
of Environmental and Financial Assistance
the WPCLF Linked Deposit Program
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12/13/99
What is a linked deposit?
The linked deposit program is a mechanism for financing certain Water
Pollution Control Loan Fund (WPCLF) projects. Instead of borrowing
directly from the Fund, a linked deposit loan is made to the applicant
by a private lending institution. The below-market interest rate for the
loan is supported by a WPCLF-funded certificate of
deposit with the lender. The Ohio WPCLF was the first SRF program
in the nation to use linked deposits.
Linked deposits were first used by the Ohio EPA in 1993 in the Killbuck
Creek watershed to establish an agricultural nonpoint source control program.
The Ohio EPA has since expanded the availablility of linked deposits to
a wider variety of projects, such as urban stormwater runoff control, stream
corridor restoration, forestry and land development best management practices,
as described in the
WPCLF Management System. In general, linked
deposit loans are available to private oraganizations and individuals for
nonpoint source projects, and for improvements such as the up-grade of
failed on-lot wastewater treatment systems.
Agricultural linked deposits
Since the Killbuck watershed program was established, agricultural linked
deposit loans have also been made in the Stillwater River, Black River,
Indian Lake, and Darby Creek watersheds. These loans were designed to provide
water quality improvements through agricultural best management practices
(BMPs). Linked deposits loans have been awarded
for BMPs such as manure storage facilities, which control animal waste
runoff from entering streams, and the use of conservation tillage equipment,
which reduces the amount of soil eroded from farm fields and deposited
in water bodies. Other funded BMPs include filter strips and grassed waterways
(which filter sediments out of runoff), fencing and alternative watering
sources to keep livestock out of streams, and the construction of a wetland
to treat process water from a dairy operation. These individually small
projects can provide a large water quality improvement when implemented
on a watershed-wide basis.
Developing a Nonpoint Source
Watershed Financing Program
Interested county Soil and Water Conservation Districts (SWCDs) contact
the Ohio EPA and express their interest in developing a nonpoint source
program in their watershed. A Watershed
Management Plan is developed which comprehensively discusses
the nature of the watershed, the pollution sources that exist, solutions
to those pollution sources, prioritization of where the emphasis should
be placed, where funding will come from, and a schedule for implementation
of the project. The writing of this Watershed Management Plan is often
a collaborative effort involving the SWCDs, the Natural Resources Conservation
Service, the Ohio EPA, and other groups or individuals working within the
watershed. The Watershed Management Plan is then reviewed by the Ohio EPA.
The Ohio EPA drafts an assessment document which describes the environmental
impacts of the actions of the proposed Watershed
Management Plan, and issues this assessment for a 30-day public
comment period. At the end of the comment period, the Ohio EPA usually
then issues a Finding of No Significant Impact, and formally approves the
Watershed Management Plan. A
Memorandum of Understanding (MOU), based
on the content of the Watershed Management Plan (WMP) is signed by the
Ohio EPA and the SWCDs (or a Joint Board if one exists). This MOU describes
how the entities will work together to implement the projects described
in the WMP, and outlines each entity's responsibilities.
During the time period that the above is occurring, local banks are
contacted (either by the Ohio EPA or by the SWCDs) to see if they would
be interested in participating in the program in their watershed. Often,
meetings are held to describe the program and answer questions. Once interested
banks are identified, each bank enters into a Participating
Bank Agreement with the Ohio EPA and the Ohio Water Development
Authority (OWDA). These agreements describe exactly how the financial transactions
will occur, as well as the procedures to be used and any banking requirements
that must be met.
When the above four items (Watershed Management Plan, Finding of No
Significant Impact, Memorandum of Understanding, and Participating Bank
Agreements) are completed, the structure for the program is in place, and
linked deposit loans can be awarded.
Awarding Agricultural Link Deposit
Loans to Applicants (Flow
Chart)
The steps for an agricultural nonpoint source loan are generally as
follows:
- A land owner develops, with county Soil and Water Conservation District
(SWCD) staff, an individual soil and water conservation plan that conforms
with a watershed management plan developed for the watershed in which the
land is located.
- The land owner obtains a Certificate of Qualification from the Board
of Supervisors of the county SWCD, identifying the proposed improvements
in the land’s soil and water conservation plan that are eligible for WPCLF
Linked Deposit Program funding.
- The land owner applies for a loan from one of the local area banks
participating in the WPCLF Linked Deposit Program.
- After the land owner presents the Certificate of Qualification, the
bank evaluates the credit-worthiness of the land owner using its criteria.
If these criteria are met, the bank then enters into a loan agreement with
the land owner.
- The bank sends an investment request form, which identifies the land
owner and the terms of the loan, and a copy of the land owner’s Certificate
of Qualification to Ohio EPA.
- Upon approval, Ohio EPA and the Ohio Water Development Authority (OWDA)
deposit with the bank, through a certificate of deposit, funds equal to
the face value of the loan to the land owner. The term of the deposit is
equal to the term of the bank’s loan with the land owner, but in no case
is longer than 20 years.
- The interest rate on the certificate of deposit is discounted below
the bank’s normal cost of funds, as determined by a comparison to the interest
rates of U.S. Treasury notes and bonds. The bank’s repayment schedule in
the certificate of deposit contains semi-annual payments of principal and
interest to the WPCLF.
- The interest rate of the bank’s loan to the land owner is reduced by
the same amount as the discount the bank received from the WPCLF.
Some Features of the Agricultural
Linked Deposit Program
- The Linked Deposit Program provides an economic incentive for farmers
to voluntarily implement best management practices to control nonpoint
source pollution. Voluntary efforts such as these may preclude the necessity
for regulatory approaches.
- At the local level, the program is administered by the county SWCDs,
which develop soil and water conservation plans, issue the Certificates
of Qualification, and monitor the improvements. Farmers are familiar with
their local SWCD and are used to working with them. The SWCDs have the
existing expertise to recommend the BMPS which should be implemented on
a particular farm.
- Land owners can work with the banks (assuming that they participate
in the program) that they reularly do business with. Many farmers prefer
to only work with the institutions that they have dealt with in the past.
- The participating banks have the existing structure and experience
to make and administer the loans. If this were not present, there would
be an administrative expense on the part of the Ohio EPA to administer
the loans.
- Participating banks earn the same amount of profit as they normally
would on their other loans. In addition, the banks that participate can
offer this as an additional service to their established agricultural customers.
- The WPCLF's Certificate of Deposit is insured by the FDIC, and thus
is secure.
- The wire transfer of funds from the WPCLF to the participating bank
normally occurs 1-2 days after the investment request form is received
by the Ohio EPA. Thus, there is very little delay in the award of funds
from the bank to the land owner.
- The reporting requirements of the SWCDs to the Ohio EPA are minimal.
Ohio EPA requires a one-page report to be filed on a quarterly basis.
For more information about a WPCLF linked deposit
loan, contact the Division of Environmental and Financial Assistance, Planning
Section, at (614) 644-2798 or send us
e-mail.
DEFA's
main page
WPCLF
page
Ohio
EPA's home page.
