Should sewage fees be included in a municipality’s revenue calculation?

The U.S. Department of the Treasury’s (“Treasury”) Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”) Final Rule defines general revenue based on the U.S. Census Bureau’s “General Revenue from Own Sources” found in the Annual Survey of State and Local Government Finances.[1] Prior to Treasury’s Final Rule, revenue from utilities was excluded from general revenue.[2] However, the Final Rule has expanded the definition of general revenue “to allow recipients that operate utilities that are part of their own government to choose whether to include revenue from these utilities in their revenue loss calculation.”[3]

In addition to the expanded definition of general revenue, the Final Rule provides municipalities the option to elect the standard allowance of up to $10 million dollars for the entire period of performance as an alternative to calculating revenue loss.[4]

Last Revised: March 3, 2022