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"necessary" even if the replaced source is not sustainable over the long term. Expediency may <br />dictate that a shorter -term solution is pursued if it is cost-effective and will prevent health issues <br />while a longer -term solution can be found. In contrast, an expansion to accommodate population <br />growth cannot be said to be necessary if it is not sustainable over its estimated useful life. <br />Not included in the list of criteria above is the requirement in the interim final rule that <br />the project be unlikely to be made using private sources of funds. Given that it may be difficult <br />to assess in a particular case what the probability of private investment in a project would be, <br />Treasury has eliminated this standard from the meaning of necessary but nevertheless encourages <br />recipients to apply funds to projects that would provide the greatest public benefit. <br />Water and Sewer Infrastructure: As stated above, Congress provided that SLFRF funds <br />are available for "necessary water, sewer, and broadband infrastructure." Treasury interprets the <br />reference to water and sewer uses consistent with the inclusion of broadband uses. Water, sewer, <br />and broadband infrastructure all involve the provision of essential services to residents, <br />businesses, and other consumers. As the pandemic has made clear, access to broadband has itself <br />become essential for individuals and businesses to participate in education, commerce, work, and <br />civic matters and to receive health care and social services. <br />Water and sewer services provided broadly to the public as essential services include the <br />provision of drinking water and the removal, management, and treatment of wastewater and <br />stormwater.305 Although governments are engaged in other infrastructure related to water, <br />including irrigation projects, transportation projects, and recreation projects, such projects go <br />305 In many jurisdictions, stormwater flows into the sewer system rather than into a separate stormwater system. The <br />separate inclusion of "water" and "sewer" infrastructure also makes clear that "water" in this context cannot refer to <br />all uses relevant to water. Given that sewer systems carry wastewater (and often stormwater), if water infrastructure <br />were to refer to all water -related infrastructure in this context, it would make the inclusion of sewer infrastructure <br />redundant. <br />269 <br />