State Revolving Fund American Iron and Steel (AIS) Requirement
The American Iron and Steel (AIS) provision requires Clean Water State Revolving Fund (CWSRF) and Drinking Water State Revolving Fund (DWSRF) assistance recipients to use iron and steel products that are produced in the United States. This requirement applies to projects for the construction, alteration, maintenance, or repair of a public water system or treatment works.
The Bipartisan Infrastructure Law of 2021 made the AIS provision permanent for DWSRF projects. For details, see Legal Authority below. The AIS provision is a permanent requirement for all CWSRF, DWSRF, and Water Infrastructure Finance and Innovation Act (WIFIA) projects.
The appropriation language sets forth certain circumstances under which EPA may waive American Iron and Steel requirements. For details, see Waiver Request Process.
On this page:
Learn about the Build America, Buy America (BABA) Act Requirements
- AIS Online Webinars
- AIS Guidance, Questions and Answers, and Training Materials
- Annual Reports
- Inquiries and Comments
- AIS Legal Authority
AIS Online Webinars
Upcoming Webinars
Check back for upcoming webinars.
View Recent Webinars
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AIS Requirement Annual Refresher Webinar (pdf)
This webinar covers the AIS Requirement, including covered iron and steel materials, documenting compliance, and roles and responsibilities.
Recent Lunch and Learn Series
Each session focused on one topic within the AIS requirement instead of a full training. The brief presentation was followed by participant questions and answers.
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AIS Construction Materials
This webinar focuses on AIS construction materials and provides several examples of construction materials and non-construction materials. Held April 21, 2021. -
AIS Compliance: Roles and Responsibilities
This webinar discusses AIS compliance roles and responsibilities covering the AIS certification letter and waiver, when products are delivered, best practices, and common issues. Held March 2, 2021. -
AIS National Minor Components Waiver
This webinar defines the waiver and compares the similarities and distinct differences between it and the national De Minimis waiver. Held October 21, 2020. - AIS Project/Product Specific Waivers
This webinar explains the different types of waivers, discusses the waiver process, and reviews the information needed to request a project/product specific waiver. Held September 30, 2020. - AIS Certification Letters
This webinar focuses on AIS Certification Letters. EPA reviews certification letters, recommended letter elements, step certifications, and best practices. Held July 29, 2020. - AIS National De Minimis Waiver for Incidental Products
This webinar explains the AIS National De Minimis Waiver, defines terms, discuses cost limitations and documenting compliance, and compares the de minimus waiver with the minor components waiver. Held June 24, 2020. - AIS compliance for Stainless Steel Nuts and Bolts in Couplings, Flanges Restraints, Saddles and Joints
This webinar reviews changes in compliance requirements since the expiration of the National Waiver on February 24, 2020, including purchase order dates, the minor components waiver, and the de minimis waiver. Held May 20, 2020. -
AIS Co-Funding with U.S. Department of Agriculture
This webinar reviews co-funding with the U.S. Department of Agriculture. Held August 26, 2020.
AIS Guidance, Questions and Answers, and Training Materials
- AIS Guidance and Questions and Answers describe how EPA implements the AIS requirement. The guidance addresses the types of projects that must comply with the AIS requirement, the types of products covered by the AIS requirement, and compliance. The guidance provides a step-by-step process for requesting waivers and the circumstances under which waivers may be granted.
- AIS Training Materials discuss how to implement the requirement, project coverage, the waiver request process, and the national waivers.
Annual Reports
American Iron and Steel 2019 Annual Report-CWSRF and DWSRF highlights the successful implementation of the American Iron and Steel requirement during State Fiscal Year 2019.
Inquiries and Comments
General inquiries and concerns regarding the American Iron and Steel requirement may be sent to: SRF_AIS@epa.gov. This includes specific questions and comments about products, projects, and availability.
Comments on CWSRF waiver requests can be submitted to cwsrfwaiver@epa.gov.
Comments on DWSRF waiver requests can be submitted to dwsrfwaiver@epa.gov.
Confidential Business Information (CBI) should not be submitted to these email boxes.
If fraud, waste, abuse or any violation of the law is suspected, the Office of Inspector General (OIG) should be contacted immediately. The OIG can be reached at 1-888-546-8740 or OIG_Hotline@epa.gov. More information can be found at the OIG Hotline website (http://www.epa.gov/office-inspector-general/epa-oig-hotline).
AIS Legal Authority
The Consolidated Appropriations Act of 2014 (Public Law 113-76) includes an American Iron and Steel (AIS) requirement. Clean Water State Revolving Fund (CWSRF) and Drinking Water State Revolving Fund (DWSRF) assistance recipients are required to use iron and steel products that are produced in the United States for projects for the construction, alteration, maintenance, or repair of a public water system or treatment works and if the project is funded through an assistance agreement executed beginning January 17, 2014 (enactment of the Act), through the end of Fiscal Year 2014.
The appropriation language sets forth certain circumstances under which EPA may waive AIS requirements. Furthermore, the act exempts projects where engineering specifications and plans were approved by a state agency prior to January 17, 2014.
On June 10 2014, the Water Resources Reform and Development Act amended the Clean Water Act (CWA) to include permanent requirements for the use of AIS in CWSRF projects. Section 608 of the CWA now contains requirements for AIS that repeat those of the Consolidated Appropriations Act of FY 2014. As such, all CWSRF projects must comply with Section 608 of the CWA for implementation of the permanent AIS requirements. Therefore, all guidances adopted for FY 2014 apply for the permanent AIS requirements for the CWSRF.
On December 16, 2014, the president signed Public Law 113-235, the “Consolidated and Further Continuing Appropriations Act 2015," which provides fiscal year 2015 full-year appropriations through September 30, 2015. This law continues the requirement for the use of AIS products in DWSRF projects. For details, see the memorandum, Application of American Iron and Steel Requirements to Fiscal Year 2015 Drinking Water State Revolving Funds under the Consolidated and Further Continuing Appropriations Act 2015.
On December 18, 2015, the president signed Public Law 114-113, the “Consolidated Appropriations Act 2016," which provides fiscal year 2016 full-year appropriations through September 30, 2016. This law continues the requirement for the use of AIS products in DWSRF projects. For details, see the memorandum, Application of American Iron and Steel Requirements for Drinking Water State Revolving Fund Projects Under the Consolidated Appropriations Act 2016.
On December 10, 2016, the president signed Public Law 114-254, the “Further Continuing and Security Assistance Appropriations Act, 2017” which provides fiscal year 2017 partial-year appropriations through April 28, 2017. This law continues the requirement for the use of AIS products in DWSRF projects. For details, see the memorandum, Application of AIS Requirements for DWSRF Projects for Fiscal Year 2017.
On September 8, 2017, the President signed Public Law 115-56, the “Continuing Appropriations Act 2018 and Supplemental Appropriations for Disaster Relief Requirements Act, 2017" which provides fiscal year 2018 partial-year appropriations through December 8, 2017. This law continues the requirement for the use of AIS products in DWSRF projects. For details, see the memorandum, Application of American Iron and Steel Requirements for Drinking Water State Revolving Fund Projects Under the Continuing Appropriation Signed September 8, 2017.
On March 23, 2018, the President signed Public Law 115-141, the “Consolidated Appropriations Act, 2018" which provides fiscal year 2018 appropriations through September 30, 2018. This law continues the requirement for the use of AIS products in DWSRF projects. For details see the memorandum, Application of American Iron and Steel Requirements for Drinking Water State Revolving Fund Projects for Fiscal Year 2018. For details, see the memorandum, Application of American Iron and Steel Requirements for Drinking Water State Revolving Fund Projects for Fiscal Year 2018.
On October 23, 2018, the President signed the "America's Water Infrastructure Act of 2018'' (AWIA), which includes several updates and revisions to the Safe Drinking Water Act (SDWA), including the Drinking Water State Revolving Fund (DWSRF) provisions. Section 2022 of AWIA amended Section 1452(a)(4)(A) of SDWA to extend the requirement for the use of American Iron and Steel (AIS) products in projects receiving financial assistance from the DWSRF during fiscal years 2019 through 2023. For details, see the memorandum, Application of American Iron and Steel Requirements for Drinking Water State Revolving Fund Projects for Fiscal Years 2019 Through 2023.
On November 15, 2021, the President signed the "Infrastructure Investment and Jobs Act" (IIJA), commonly known as the Bipartisan Infrastructure Law, which amends Section 1452(a)(4)(A) by removing an expiration date for the AIS provision for DWSRF. For details, see the memorandum, Memorandum: Implementation of the Clean Water and Drinking Water State Revolving Fund Provisions of the Bipartisan Infrastructure Law (pdf)