ARPA - Revenue Loss

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Blaine Fritts

May 13, 2021, 10:54:08 AM5/13/21

Does the definition of “General Revenue” include CIP revenues like REET, and Traffic & Park Fees?  I am leaning toward the answer being, “Yes”. 

  1. It is not expressly excluded.
  2. It is a source that is generated from economic activity.
  3. These sources are primarily used for capital infrastructure (roads, parks, facilities) which appear to be allowable uses of the “Revenue Loss” funds.


Thoughts?  Are there any revenues, other than the excluded ones (refunds, other correcting transitions, insurance proceeds, sale of investments, issuance of debt, agency/trust, utility, and fed funding), that you are thinking should be excluded?  What about interest earnings?


Blaine Fritts | Finance Director | City of Woodinville

d: (425) 877-2261 | m: (425) 439-4534 |e:


Woodinville City Hall, 17301 133rd Ave NE, Woodinville WA 98072

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Brad Posenjak

May 13, 2021, 1:06:18 PM5/13/21
to Blaine Fritts,



I spent a while yesterday trying to figure out which of our revenues would be included in the “general revenue” category. Footnote 116 of Treasury’s Interim Final Rule points to a website, that when you dig in, shows the categories included in “General Revenues from Own Sources” (see attached spreadsheet “18slsstab1b.xlsx”).


At this point, I am also assuming that REET and any fees would be included in the General Revenues. I also attached the spreadsheet “Revenue Compare.xlsx” in which I started to analyze the City of Wenatchee’s revenues. I basically took a data dump of all our revenue accounts and then started removing any that I thought wouldn’t be eligible based on the guidance. This is my early interpretation of the rules. If anyone wants to dig in, I’d be interested in your comments.


Currently, my largest point of contention is revenue from sales of property. According to the attached “18slsstabb.xlsx” document, sale of property is included in “General Revenues from Own Sources”. Unfortunately for us, we had a couple large one-time property sales in 2020 which is inflating our 2020 “general revenues.” Even though our operating revenues were down from 2019 to 2020, our property sales make 2020 look way better than it should, and therefore, make us ineligible for revenue replacement in 2020.


I’m hoping to get clarification from Treasury, but at this point, I cannot find how to comment on this document. The comment website they point to doesn’t appear to be ready for comment on this document yet.


I’d be interested to have more conversation about the interpretations of “general revenue” for revenue replacement.


Also, I was disappointed to see that they specifically removed the ability to cover general police salaries… like we were able to do with the CARES funding. Now we have to get more creative.




Brad Posenjak

Finance Director

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301 Yakima Street, 3rd Floor • PO Box 519 Wenatchee, WA 98807-0519

Office: (509) 888-3610 • Email:

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Revenue Compare.xlsx
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