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calculated by recipients for other purposes, and requested clarifications regarding a number of <br />components, including the definition of revenue. Commenters also asked for clarification on the <br />relationship between revenue loss calculations across different calculation dates. Other <br />commenters argued that the revenue loss formula does not precisely capture the nuances of local <br />revenues or their particular situation. For example, some commenters stated that requiring that <br />revenues be aggregated fails to capture decreases in revenue sources that cannot easily be made <br />up for with other revenue sources. <br />Treasury Response: In the final rule, Treasury is largely maintaining the revenue loss <br />formula as set forth in the interim final rule. To address comments that the formula for <br />calculating revenue loss was difficult to apply, Treasury is including an option for recipients to <br />use a standard allowance for revenue loss. Specifically, in the final rule, recipients will be <br />permitted to elect a fixed amount of loss that can then be used to fund government services. This <br />fixed amount, referred to as the "standard allowance," is set at $10 million total for the entire <br />period of performance. Although Treasury anticipates that this standard allowance will be most <br />helpful to smaller local governments and Tribal governments, any recipient can use this standard <br />allowance instead of calculating revenue loss pursuant to the formula above, so long as recipients <br />employ a consistent methodology across the period of performance (i.e., choose either the <br />standard allowance or the regular formula). Treasury intends to amend its reporting forms to <br />provide a mechanism for recipients to make a one-time, irrevocable election to utilize either the <br />revenue loss formula or the standard allowance. <br />The $10 million level is based on average revenue loss across state and local <br />governments, taking into consideration potential variation in revenue types and losses and <br />continued uncertainty faced by many recipients regarding revenue shortfalls. To calculate this <br />240 <br />