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InRecap

WIFIA FCRA Criteria: Narratives and New Criteria

A summary of the Pro-Criteria Narrative, the Pro-Eligibility Counter-Narrative and the New Criteria, updated.

Non-Federal-FCRA-Narrative-and-Counter-Draft-091123-InRecap-

PDF of the document

Background here: FCRA Non-Federal: Truth, Narratives, and the New Criteria

This entry was posted in Uncategorized on September 12, 2023 by inrecap.

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← FCRA Non-Federal: Truth, Narratives, and the New Criteria The Background Section of OMB’s WIFIA Criteria, Line-by-Line →

Recent Posts

  • How a Reformed WIFIA Could Use $1 Billion in Funding
  • EPA WIFIA Loan Program Reform in FY26 Reauthorization
  • Going Full Narrative: “Without WIFIA’s Free Interest Rate Options, Children in Silicon Valley Would Be Dying of Thirst!”
  • NACWA Tells Us They Are Shocked, Shocked!
  • WH FY27 Budget: EPA WIFIA Funding Losses of $3.1b FY18-FY26 Est.
  • How $2.1b of Taxpayer Resources Could Have Been Used for Sub-UST SWIFIA Loans
  • EPA WIFIA’s Funding Losses: $2.1 Billion of Real Taxpayer Resources. For What, Exactly?
  • Comparison of EPA WIFIA and Solyndra Funding Losses
  • Outline of Credit Subsidy Estimate Model for Predictable WIFIA Loan Funding Losses
  • EPA WIFIA: Program Statistical Models Predictive of Loan Outcomes, Per OMB Circular A-129
  • EPA WIFIA: Impact of Loan Options Must Be Included in Credit Subsidy Estimates, Per OMB Circular A-11
  • EPA WIFIA: Lessons from a Federal Coin-Flip Program
  • EPA WIFIA: Bad Budgeting Supports Misleading Narratives
  • EPA WIFIA: Bad Budgeting Means Bad Policy
  • Five Potential Issues for EPA WIFIA FY26 Reauthorization
  • CBO Scoring of EPA WIFIA Reauthorization Legislation Will Need to Consider Actual Results FY2018-FY2025
  • The Near-Certainty of EPA WIFIA Funding Losses Was Obvious in 2021
  • Apportioning Discretionary Appropriations for Expected WIFIA Portfolio Funding Losses
  • Will WH FY27 Budget Show EPA WIFIA Estimated FY26 Mandatory Spending Over $1 Billion?
  • Is EPA WIFIA a Mandatory Program?
  • OpenOMB: Data on EPA WIFIA Direct Financing Account Apportionments, Credit Subsidy for All Loans
  • OpenOMB: Data on EPA WIFIA Program Account Apportionments
  • No Skin in the Game: Using PIA To Cover an ‘Indifference Deficiency’
  • Draft Request for ‘Legal Decision’ from GAO Re Possible EPA WIFIA and OMB ADA Violation
  • EPA WIFIA Self-Imposed Restrictions on Resets Imply Recognition of Probable Funding Losses
  • EPA WIFIA’s Likely 20% Realized Loss Rate on Disbursed Loans, Coercive Deficiencies, etc.
  • EPA WIFIA Loan Cost Estimates Should Include Near-Certain Funding Losses
  • EPA WIFIA’s Violation of Anti-Deficiency Act if Predictable Funding Losses are Excluded from Loan Commitment Apportionment
  • Two Technical Clarifications – 55Y/35Y Difference, Mandatory Spending
  • EPA WIFIA: Deception, All the Way Down (Part 1)
  • FCRA Criteria for EPA WIFIA’s Predictable Interest Rate Re-Estimates?
  • Some Context for AWIFAA 26
  • Two ‘Crony Loaners’ Require Reauthorization in 2026
  • Crony Loan Programism
  • Why Did OMB Focus on the FCRA Criteria — And Ignore WIFIA’s A-129 and Mandatory Spending Issues?
  • Radical Solution: A New WIFIA for General Water Infrastructure at Interior Department
  • New WFM Article: Continuing to Explain What Is Really Happening at WIFIA, On Multiple Levels
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  • WIFIA 55Y Case Comparison Update 01082026
  • Latest Spending Bill: CWIFP Non-FCRA Ineligibility and WIFIA Pointless Funding
  • Expanding the Scope for WIFIA’s Eligible Combinations of Small Projects
  • The Zeldin Letters
  • A Declining WIFIA Program Needs Amendments — Not More Funding, Narrative or Spin
  • 55-Year WIFIA Loan Term Amendment for Long-Lived Projects
  • Slicing Up the Federally Subsidized Infrastructure Finance Pie
  • Senate S.3293’s Non-FCRA Provisos and HR. 6229’s FCRA Amendment — Good Faith Policy or End Run?
  • WIFIA Reform: Now the Time Has Come
  • WIFIA Decline: Harder Questions
  • Addressing Large Mandatory Spending at the WIFIA Loan Program
  • POSIWID: The Purpose of a System is What It Does
  • To Preserve WIFIA’s Interest Rate Management Features, Enact the 55-Year Loan Term
  • An ‘Occasionally Useful Option’
  • Bond Buyer: WIFIA vs. Bonds
  • WIFIA Decline: A Time for Hard Questions?
  • WIFIA’s Solyndra-Scale Timebomb?
  • GWI Article Section: “The Slow Demise of WIFIA’
  • Initial Thoughts on WIFIA Loan Volume Decline 2022-2024
  • A New Deal for Federal Water Infrastructure Finance?
  • WIFIA’s Decline and…What?
  • WIFIA Collusion Risk Amendments in Five Bullets
  • Collusion Risk Amendment: Plan B
  • Addressing Collusion Risk in Federally Financed Cost-Shares
  • A New Narrative Approach to the FCRA Issue
  • Revising the 2020 WIFIA FCRA Criteria, FWIW
  • A Third Party and Federal Infrastructure Financing Reform
  • AWWA SOTWI 2025 Survey: Context for Federally Subsidized Finance
  • States Should Fund Their Own Water Infrastructure – Um, Except When Muni Bonds Are Used?
  • WH 2026 Budget WIFIA Cut — Update Re Carryover Funding
  • WH 2026 Budget for CWIFP, TIFIA
  • WIFIA Cut in the WH 2026 Budget Technical Supplement?
  • The Neo-Narrative Could, In Fact, Fail
  • The Neo-Narrative Wars
  • [Your Name] Asks: “Abundance” for Whom?
  • “As soon as the federal loan money goes cha-ching…
  • WSJ: ‘Save Us From the CBO’
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