ASCE Submits Comments to US EPA on the Use of QBS to SRF Programs


ASCE recently submitted comments to the US Environmental Protection Agency (EPA) on guidance the agency developed following the the recently enacted Water Resources Reform and Development Act (WRRDA) of 2014. WRRDA makes a number of changes to the Clean Water State Revolving Fund (CWSRF) program administered by EPA and recently developed guidance for its regional offices on how to implement the new provisions.

One of the major changes is that all architectural/engineering (A/E) contracts under the CWSFR must now comply with federal or state-approved Qualifications-Based Standards (QBS). ASCE has advocated for QBS provisions to apply to the SRF program for over a decade and applauds the new WRRDA language. QBS provisions ensure the government and citizens who rely on critical infrastructure receive the best possible A/E services based on competence, qualification, background and track record of competing firms, subject to negotiation of a fee that is fair and reasonable. QBS procedures were originally established by the Brooks Architect-Engineers Act of 1972.

Our three comments to EPA were straight forward:

  • Follow the letter of the law and ensure that A/E contracts under the CWSRF are backed by federal or state approved QBS provisions.
  • Ensure firms are ranked based first on qualification. Cost must be negotiated during the second step of the procurement process.
  • Require all projects co-mingled with SRF funds to also be subject to QBS provisions.

If you would like to see ASCE’s full letter to the EPA, click here.

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