U.S. Treasury Releases Additional FAQs on ARPA; League Submits Comments on Interim Rule

On July 14, the U.S. Treasury Department posted several additional FAQs about the Coronavirus State and Local Fiscal Recovery Funds component of the American Rescue Plan Act (ARPA).

Treasury has been updating its FAQ document periodically to help clarify questions about the Interim Rule relating to ARPA. Treasury is trying to respond as quickly as possible to municipal concerns.
Last week's FAQ update includes clarification on a number of points that have been raised by communities, including:

  • Identifying constituent entities of government for the purpose of calculating revenue loss
  • Treatment of utility revenue for the purpose of calculating revenue loss
  • Use of funds to support energy or electrification infrastructure that would be used to power new water treatment plans and wastewater systems
  • Use of funds for stormwater management projects, such as a culvert replacement
  • Use of funds for road repairs directly related to eligible water or sewer projects
  • Use of funds to build or upgrade broadband connections to schools and libraries
  • Applicability of the Davis-Bacon Act to eligible infrastructure projects
  • Pooling of funds for regional projects
  • Funding projects with both ARP funds and other sources of funding
  • Use of funds to make loans or other extensions of credit
  • Use of funds for outreach to increase uptake of federal assistance like the Child Tax Credit or federal programs like SNAP
  • [Update to FAQ 10.3] Interest earned on CSFRF/CLFRF funds
The full FAQ document, which includes FAQs from the Treasury's original May 10 publication date, the previous updates, and the most recent July 14 update, can be found here: home.treasury.gov/system/files/136/SLFRPFAQ.pdf
Last week, the League submitted comments to the U.S. Treasury on the Interim ARPA Rule. We touched on several outstanding questions we have collected from municipalities across Wisconsin. The deadline for submitting comments to the Treasury was July 16.

Read the League's comments on the Interim Rule here:

Federal Office of Management and Budget Rejects Redefining MSAs as communities with populations over 100,000

After overwhelming municipal opposition, the federal Office of Management and Budget (OMB) has backed away from a plan to change the way it defines metropolitan statistical areas. The initial proposal would have raised the minimum core-city size for a Metropolitan Statistical Area (MSA) from 50,000 to 100,000 residents. The change would have reclassified 251 currently metropolitan cities as nonmetropolitan, based on current population figures. 

Last week, the OMB announced that it did not accept the initial recommendation to raise the MSA core population threshold in the 2020 standards, and has decided to leave the current population threshold of 50,000 in place. A change to the fundamental criteria that determine whether an area is considered metropolitan would cause disruption to statistical programs and products, and would be difficult for the statistical agencies to implement. OMB decided that there is insufficient justification at this time to raise the threshold to 100,000 and that further research is necessary before deciding whether to change the criteria that determine whether an area is considered metropolitan.

Read the OMB July 13 press release.

Read the League's comments to the OMB here.