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In selecting these thresholds, Treasury recognized that capital expenditures vary widely <br />in size and therefore would benefit from tiered treatment to implement eligibility standards while <br />minimizing administrative burden, especially for smaller projects. For example, Treasury <br />selected $1 million as a threshold for whether a recipient needs to complete a Written <br />Justification as well as a threshold under which capital expenditures would be presumed <br />reasonably proportional. Treasury estimates that $1 million would encapsulate the costs of a <br />significant portion of equipment or small renovations. These types of smaller projects are often a <br />necessary and reasonably proportional part of a response to the public health emergency; <br />therefore, the $1 million threshold provides a simplified pathway to complete smaller projects <br />more likely to meet the eligibility standard. At the same time, Treasury selected $10 million as <br />the threshold for more intensive reporting requirements, estimating that projects larger than $10 <br />million would likely constitute significant improvements or construction of mid- or large -sized <br />facilities. As discussed above, given their scale and longer time to completion, these types of <br />larger projects may be less likely to be reasonably proportional responses. The $10 million <br />threshold also generally aligns with thresholds in other parts of the SLFRF program, such as for <br />enhanced reporting on labor practices. <br />Expenditures from closely related activities directed toward a common purpose are <br />considered part of the scope of one project. These expenditures can include capital expenditures, <br />as well as expenditures on related programs, services, or other interventions. A project includes <br />expenditures that are interdependent (e.g., acquisition of land, construction of the school on the <br />land, and purchase of school equipment), or are of the same or similar type and would be utilized <br />for a common purpose (e.g., acquisition of a fleet of ambulances that would be used for COVID- <br />19 emergency response). Recipients must not segment a larger project into smaller projects in <br />202 <br />