2024-12-16 Memo ARPA reallocation under Revenue Replacement E911
TO: Board of County Commissioners
FROM: Becky Butler, Budget and Risk Director
DATE:12/16/2024
SUBJECT: Deobligation and Reallocation of American Rescue Plan Act (ARPA) State and
Local Fiscal Recovery Funds (SLFRF) from the E911 Communication Radio Project to Public
Safety Salaries under Revenue Replacement: Provision of Government Services
Purpose:
This memorandum serves to formally document the deobligation of $2.2 million in SLFRF
funds previously allocated to the E911 Communication Radio Project and the reallocation of
these funds to Public Safety salaries under the Revenue Replacement category. This
adjustment aligns with the U.S. Treasury’s guidelines and ensures compliance with funding
requirements while maintaining support for the E911 project.
Background:
The County previously allocated $4.5 million in SLFRF funds to the E911 Communication
Radio Project. Following a review of the County’s overall SLFRF strategy and the updated
guidance from the U.S. Treasury, it has been determined that reallocating these funds under
the Revenue Replacement category for Public Safety salaries represents the best use of
funds. This change also ensures the County can fully utilize the allowable $10 million under
the Revenue Replacement provision for general government services.
The E911 Communication Radio project’s costs were decreased after final bids were
received and will continue to be funded through a transfer of $2.2 million from the
unassigned Current Expense Fund balance to the Communications Building and Equipment
Capital Fund No. 3300, ensuring no interruption of the project’s progress.
Rationale for Reallocation:
Compliance with SLFRF Guidelines: Reallocating the funds to Public Safety salaries is
explicitly allowable under the U.S. Treasury’s Compliance and Reporting Guidelines for the
use of funds under the Expenditure Category (EC) 6.1 Revenue Revenue Replacement (Lost
Revenue): Provisions of Government Services as stated in the attached memo from the
Auditor’s Office.
Risk Mitigation: The reallocation reduces the risk of funds being unspent or
unallocated by the statutory deadline of December 31, 2024.
Flexibility and Efficiency: Utilizing SLFRF funds for eligible Public Safety salaries frees
up general fund resources, allowing the County to support other critical needs.
E911 Project Funding Stability: The project’s funding remains intact, supported by a
transfer from the unassigned Current Expense Fund balance to the Capital Fund.
Eligibility Review:
This reallocation has been reviewed and approved by the County’s grant management team,
including the Auditor’s Office and BerryDunn, our grant consulting partner. The review
confirms that the proposed use complies with ARPA and SLFRF requirements and maintains
the integrity of the County’s financial management.
Recommendation:
1. Approve the deobligation of $2.2 million in SLFRF funds from the E911
Communication Radio Project.
2. Authorize the transfer of $2.2 million from the unassigned Current Expense Fund
balance to the Capital Fund to support the E911 Communication Radio Project.
3. Reallocate up to $6.9 million toward Public Safety salaries under the Revenue
Replacement EC 6.1.
Conclusion:
This reallocation aligns with ARPA and SLFRF guidelines, optimizes the use of funds, and
ensures timely obligation or expenditure by the statutory deadline. It represents the lowest-
risk approach while maintaining critical funding for the E911 Communication Radio Project.
We recommend the Board’s approval of this reallocation.