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Vinod Jose

8 min· water

Forty years on Stinson Creek: what one small plant's SRF record says about the end of IIJA

Fulton, Missouri just got $5.8 million from the Clean Water SRF, two weeks after IIJA's supplemental money ended. Its public record shows a 2015 SRF loan that sat mostly undrawn for six years, and a grant cap that has already gone back to its pre-IIJA level.

On October 14, the Missouri Department of Natural Resources announced $5.8 million for the City of Fulton, a town of about 12,500 in Callaway County. The package is a $4.3 million Clean Water State Revolving Fund loan over 20 years and a $1.5 million grant, with $1.5 million from the city. It pays for nutrient removal at the city's wastewater plant, with completion expected in September 2027.

The announcement came two weeks after the Infrastructure Investment and Jobs Act's supplemental SRF money ended on September 30. Water associations are now pressing Congress to put SRF money into the next water bill. The stopgap spending bill keeps regular funding flowing through December 11.

My first take on the Fulton news was simple. With the IIJA money gone, SRF dollars get tighter, so the utilities that already hold a loan are the ones with cash to spend now. I believe that is half right. Fulton's public record tells a longer story, and it changed what I think a "loan in hand" means.

1. One creek, forty years

Fulton's plant was built in 1985, according to DNR, with major upgrades in 1997, 2012 and 2015. It discharges to Stinson Creek, which DNR first listed as impaired in 1994. A total maximum daily load (TMDL) set nutrient targets for the creek in 2010.

The years after that were hard on the city. Around 2011 to 2013, the city learned the plant could not meet the new limits, and the first estimates for the fix came in around $60 million. In 2014 the Clean Water Commission approved a variance, and the city put a sewer bond to voters. DNR revised the TMDL in December 2021. The current permit, issued in 2023, sets annual caps that take full effect on December 1, 2033: 4,460 pounds of phosphorus a year (0.5 mg/L) and 89,202 pounds of nitrogen (10 mg/L).

The price of meeting the limit has moved as much as the limit itself. Here are the estimates in order: about $60 million at first, about $13 million for a first phase in 2013, $5 million from DNR against $30 million from HDR, the city's engineer on the 2013 plan, in 2022, $4.15 million in the facility plan filed with EPA's needs survey that year, and about $7.5 million for the design-build project now under contract. These are not quotes for the same work. The scope changed, and so did the TMDL. That is the point. A single number in a press release hides a decade of decisions.

First estimates, about 2012$60M
Phase I plan, 2013about $13M
HDR, 2022$30M
DNR, 2022about $5M
Facility plan, EPA needs survey, 2022$4.15M
Design-build project, 2026about $7.5M
Published estimates for meeting Fulton's nutrient limits, in millions of dollars, in the order they appeared. The scopes differ, and the TMDL was revised in 2021, so these are not quotes for the same work.Fulton Sun (Jun 4, 2013; Mar 10, 2014; Jan 19, 2022); EPA Clean Watersheds Needs Survey 2022; Fulton Public Utility Board minutes, Mar 23, 2026.

2. What the money buys

The discharge data explains the project better than the announcement does. Fulton's effluent phosphorus has averaged about 2 mg/L in every year since 2015. In 2025 that came to about 10,700 pounds (derived from EPA's discharge data), against a final cap of 4,460. The plant has to cut phosphorus by about 58% (derived).

Nitrogen is a different story. The 2025 load was about 57,900 pounds (derived), already under its final cap of 89,202. Nitrogen ran above that cap in most years before 2024.

Nutrient2025 loadFinal capChange needed
Total phosphorusabout 10,700 lb4,460 lb (0.5 mg/L)cut about 58%
Total nitrogenabout 57,900 lb89,202 lb (10 mg/L)already under
Fulton's 2025 discharge against the final annual caps that apply from December 1, 2033. Phosphorus is the gap; nitrogen is already under its cap. The 2025 loads and the cut needed are derived from EPA discharge data.EPA ECHO effluent data for NPDES MO0103331 (2015-2025); Missouri DNR permit MO0103331 and fact sheet, effective Dec 1, 2023.

DNR's environmental review, dated November 18, 2025, lists the work: oxidation-reduction potential (ORP) instrumentation and controls, supplemental mixing in the existing oxidation ditch, a chemical feed system to trim phosphorus at the final clarifier splitter box, and a new building to house the compressors, tanks and pumps. It is a targeted phosphorus fix on an existing plant, not a new plant.

3. Three trips to the SRF

Fulton has borrowed from Missouri's Clean Water SRF three times. The state's annual reports list a $6 million loan in June 1997 and a $13 million loan in December 2015. The third is this year's.

The 2015 loan is the one that changed my thinking. The city's audits describe it as Sewerage System Revenue Bonds, Series 2015, up to $13 million at 1.22% interest, repaid through 2031. The project it paid for was completed in 2018. Yet by the end of 2023, the city had drawn only $4,766,226 of it. By the end of 2024 the drawn amount was $7,884,949, so about $3.1 million was drawn in a single year (derived), six years after that project closed. In May 2024, the utility board's minutes record staff saying the nutrient work was being funded from "a 2015 Bond that has not been fully used along with applying for SRF grants." About $5.1 million of the 2015 loan has never been drawn (derived).

An SRF loan is not cash in a bank account. In Missouri's direct loan program, the state manages and invests the bond proceeds on the city's behalf, and the city draws on them as the work is paid for. A "loan in hand" is a ceiling, and Fulton held about $8 million of unused ceiling for six years.

YearLoanWhat the record shows
1997$6.0MTreatment plant and collection system improvements
2015$13.0M1.22%, through 2031. Project done 2018. $4.77M drawn by 2023, $7.88M by 2024, about $5.1M never drawn
2026$4.31MPlus a $1.5M grant, for nutrient removal. Revenue bond approved Aug 25, 7-0
Fulton's three Clean Water SRF loans. The 2015 loan was drawn well below its ceiling, and the city went back to it in 2024 for the nutrient work. Amounts drawn are from the city's audits; the one-year 2024 draw and the undrawn balance are derived.Missouri Clean Water SRF annual reports 2013-2025 (loan lists); City of Fulton Annual Comprehensive Financial Reports 2021-2025 (long-term debt note); Missouri DNR award release, Oct 14, 2026; Fulton council minutes, Aug 25, 2026.

The 2026 loan took the same path. The council approved the design-build contract and the SRF resolution on June 9, 2026, both 6–0. On August 25 it approved the application and an ordinance for a revenue bond "not to exceed $4,314,050.94," both 7–0. That is the $4.31 million SRF loan in DNR's announcement.

So the buying decision came long before the award. The council approved a preliminary design-build agreement with Burns & McDonnell in September 2024, 7–0, and the utility board's minutes date the project's start to October 2024. The scope was in the August 2025 facility plan. By the time the October 2026 press release went out, the contractor had been chosen for two years.

4. The grant that won't be there next year

Missouri's adopted Intended Use Plans show what IIJA changed in one state. In the FFY2022 plan, before IIJA, Missouri had $448.6 million for loans and $32.0 million for grants and principal forgiveness. In the FFY2027 plan adopted on October 14, it has $501.9 million and $162.1 million.

Lending stayed between about $386 million and $502 million. The grant pot grew about fivefold (derived). That is the IIJA effect in Missouri: the general supplemental grants required states to give a large share as subsidy, so the extra money arrived as grants, not as more lending.

FFY2022, before IIJA$32.0M
FFY2024$91.1M
FFY2025$125.3M
FFY2026, Fulton's year$153.0M
FFY2027$162.1M
Grants and principal forgiveness available in Missouri's Clean Water SRF, in millions of dollars, by adopted plan year. Lending stayed between about $386 million and $502 million over the same years. FFY2027 is the last plan built on IIJA capitalization grants.Missouri DNR Clean Water SRF Intended Use Plans, adopted FFY2022, 2024, 2025, 2026 and 2027. The FFY2023 adopted plan was not available.

Fulton's $1.5 million grant came from the Water Quality Incentive Grant, which Missouri offers for upgrades a permit requires. Its cap was $1.0 million before IIJA, rose to $1.5 million in the FFY2026 plan, and is back to $1.0 million in the plan adopted on October 14. The plan doesn't say why. Fulton got in while the cap was raised.

The bigger change hasn't arrived yet. FFY2027 is the last Missouri plan built on IIJA capitalization grants. The FFY2028 plan, which I expect DNR to draft next summer, is where the drop lands, unless Congress appropriates more. The Senate's water resources bill would reauthorize the SRFs through 2030. The House version, passed 415–9 on September 16, does not. Even a reauthorization is not an appropriation. In Missouri, the "SRF money ran out" story is a story for next year's plan.

5. Where the decision shows up first

For utility finance staff and for anyone who sells to utilities, Fulton's record shows where each step appeared before the announcement.

  1. The permit. The compliance schedule tells you what has to change and by when. Fulton's final caps apply in 2033.
  2. The state's adopted Intended Use Plan. Read the project list and the subsidy terms, not just the total. The grant cap told the IIJA story better than the headline number did.
  3. Council resolutions. The authorizing resolutions and the revenue bond ordinance came months before the announcement.
  4. Utility-board minutes. This is where the schedule moves. In October 2025, staff expected work from spring 2026 to spring 2027. By May and June 2026, it was "late June or early July" and 18 months, which points to about January 2028 (derived). DNR's release still says September 2027.
  5. The audit's long-term debt note. The line "had been drawn on these bonds" shows whether a loan is being spent.

If you only do one thing this week, pull your state's adopted Intended Use Plan for 2027 and find the line that sets the subsidy cap. Then compare it with last year's.

What I don't know yet

I could not confirm that construction has started. The last posted minutes say it "will likely start late June or early July," and none since say it began. Fulton's discharge data shows more permit violations in August 2026 than in any month since 2015, but nothing in the record ties them to construction. I also don't know whether a chemical phosphorus trim will carry the plant to 0.5 mg/L by 2033. If it doesn't, Fulton's next project will be financed in a post-IIJA SRF, and it will be the fourth trip.

The next marker is Missouri's FFY2028 plan, when the draft comes out.

AquaIntel puts the permit, the state plan, the minutes and the audit for each utility side by side, so the decision shows up before the press release does.

I write about US water utility buying signals every two weeks. Subscribe free on Substack.