At the time the interim final rule was published, the average annual growth across all state and local government “General Revenue from Own Sources” in the most recent three years of available data (2015-2018) was 4.1%, which was presented as one option for the growth adjustment. Since the interim final rule was published, 2019 data has been made available, which increases this rate to 5.2%. 

The City of Council Bluffs Finance Department staff have run the calculations with the new 5.2% growth increasing the dollar amount to be obligated to Revenue Loss.

Funds obligated under Revenue Loss are allowed for more uses than the other ARPA funds, so the full amount allowed should be obligated to Revenue Loss