The first part of this WFM article raised awkward questions about WIFIA’s decline 2022-2024.

The second part goes further:

• If WIFIA’s growth and subsequent decline was primarily the result of displacement of two other sources of federally supported finance, then what’s the additionality of the Program? Total capex trends don’t seem to reflect any.

• WIFIA loan overlap with SRFs and tax-exempt bonds was recognized at the outset of the Program in 2014 — now that actual results 2018-2024 seem to confirm that overlap, what’s next? This is fine?

• OMB Circular A-129 is pretty specific about additionality and non-overlap as requirements for federal credit programs. How was WIFIA in compliance with these requirements? Under the current administration, can non-compliance be ignored for the next three years?

Now add this to the mix — WIFIA Mandatory Spending — and an open-ended question must be asked: What, if anything, can be done?

Reform.