Can a municipality account for a municipal airport’s lost revenue when calculating total lost revenue for the municipality under the ARP?

Yes. A municipal airport’s revenue can be included when calculating total lost revenue for a municipality under the American Rescue Plan Act of 2021 (“ARP”) Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”).

U.S. Department of the Treasury (“Treasury”) guidance directs municipalities to determine which of its revenue streams fall under the definition of “general revenue,” a term that is based on (though not identical to) the Census Bureau’s concept of “General Revenue from Own Sources” as published in the Annual Survey of State and Local Government Finances.[1]

Treasury’s Final Rule defines “general revenue” as “money that is received from tax revenue, current charges, and miscellaneous general revenues.”[2] Airport revenue would most likely fall under the category of “current charges.”[3]

Treasury also states that revenues from all commercial-type activities of a recipient’s government are covered by the Final Rule’s definition of “general revenue.” However, municipalities may decide whether to include or exclude revenues from operations of publicly owned and controlled water supply systems, electric power systems, gas supply systems, and public mass transit systems.[4] Treasury further confirms that commercial-type activities include revenue from airports.[5]

CSLFRF Frequently Asked Question #3.14 may assist municipalities in addressing questions about whether a particular entity performing commercial-type activities can be considered a part of a recipient’s government, and as such, whether its revenue is covered by the Final Rule’s definition of “general revenue.”[6]