American Iron and Steel

Where AIS Lives

The American Iron and Steel provision was first enacted in the Clean Water Act State Revolving Fund through the FY2014 appropriation and has been re-authorized continually since. It applies to projects funded through the EPA Clean Water State Revolving Fund (CWSRF) and the Drinking Water State Revolving Fund (DWSRF). USDA Rural Development water and wastewater programs carry parallel AIS language and apply the same standard.

For water and wastewater utilities operating projects funded through these programs, AIS is the controlling federal domestic content standard. State Revolving Fund administrators issue program-specific guidance that implements AIS at the state level and references EPA technical guidance for product scope and documentation.

What AIS Covers

AIS applies to iron and steel products that are permanently incorporated into the project. For water and wastewater projects, that scope includes pipe, fittings, flanges, valves, hydrants, manhole covers, and structural steel. Components and subcomponents made of iron or steel that are permanently incorporated must meet the AIS standard. Components made of other materials, or temporary construction equipment, fall outside AIS scope.

The standard requires that all manufacturing processes from the initial melt through coating and finishing occur in the United States. A ductile iron pipe fitting cast domestically from imported pig iron does not qualify because the melt step occurred outside the United States. A steel flange forged domestically from imported billet does not qualify for the same reason.

Documentation

• AIS Step Certification: the EPA-standard format certifying that all manufacturing processes for the iron and steel products occurred in the United States.
• Mill Test Reports with heat number and domestic mill location.
• Project-Specific Compliance Letter referencing the SRF program and project number.
• Submittal Package: when a project submittal is required for AIS scope review, we provide the documentation in the project office format.

Waivers

EPA may grant AIS waivers for unavailability, unreasonable cost, or public interest. Waivers are issued at the project level and are time-bounded. We do not assume waivers will be granted. For standard water and wastewater iron and steel products including ductile iron pipe, steel flanges, gate valves, and butterfly valves, domestic product is available and AIS-compliant supply chains are established.

Why AIS Is Stricter Than It Looks

AIS includes coatings and linings within the manufacturing process scope when those coatings or linings are applied at the manufacturing plant. A ductile iron pipe coated with cement mortar at the casting mill must have the mortar applied domestically. A field-applied coating is generally treated as a separate process and not subject to AIS. The line between in-plant and field-applied coating is sometimes ambiguous on submittal review. The project office decides.